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Patna High Court

Ravindra RaiversusThe State of Bihar

Decided
Disposal
ALLOWED

Holding

The High Court set aside the lower court’s order rejecting anticipatory bail and granted bail to the appellant.

Summary

The appellant, Ravindra Rai, was charged under several IPC sections (420, 147, 341, 342, 363, 323, 504, 506) and Sections 3(1)(r), (s), (w) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act for allegedly forcing the informant to register a sale deed of his house and abusing him with caste slurs. The FIR was lodged eight months after the alleged incident, and the appellant claimed innocence and that the delay was unexplained. The trial court, an Exclusive Special Judge, rejected the appellant’s anticipatory bail application. On appeal, the Patna High Court examined the seriousness of the offences, the unexplained delay in filing the FIR, and the allegations of coercion and caste abuse. The High Court set aside the lower court’s order, allowed the appeal, and directed that the appellant be released on bail upon furnishing a bail bond of Rs. 10,000 with two sureties, subject to the conditions of the Special Judge.

Issues considered

  • Whether the appellant is entitled to anticipatory bail despite the seriousness of the offences alleged under the IPC and the SC/ST Act.
  • Whether the eight‑month delay in lodging the FIR is a sufficient ground to deny anticipatory bail.
  • Whether the alleged coercion to register a sale deed and caste‑based abuse justify refusal of bail.

Legislation cited

Subjects

  • anticipatory bail
  • delay in FIR
  • forced sale deed
  • caste abuse
  • SC/ST Act
  • IPC offences
  • bail conditions

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                                  CRIMINAL APPEAL (SJ) No.4404 of 2025
                       Arising Out of PS. Case No.-1015 Year-2024 Thana- MAHUA District- Vaishali
                 ======================================================
                 Ravindra Rai son of Late Budhan Rai Resident of Village- Mahua Singh Rai,
                 P.S.- Mahua, District- Vaishali

                                                                                   ... ... Appellant/s
                                                        Versus
           1.    The State of Bihar
           2.    Arjun Manjhi son of Late Vishwanath Manjhi Resident of Village- Mahua
                 Singh Rai, P.S.- Mahua, District- Vaishali

                                                           ... ... Respondent/s
                 ======================================================
                 Appearance :
                 For the Appellant/s      :        Mr. Pranav Kumar, Advocate
                                                   Mr. Rajeev Ranjan No. II, Advocate
                                                   Ms. Priyanka Kumari, Advocate
                 For the State            :        Ms. Usha Kumari 1, APP
                 For the Informant        :        Ms. Rina Sinha, Advocate
                                                   Mr. Dhirendra Prasad Sinha, Advocate
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE NAWNEET KUMAR
                 PANDEY
                                       ORAL ORDER

3   23-02-2026                       Heard the learned counsel for the appellant as well

                   as the informant and learned APP for the State.

                                     2. This memo of appeal has been preferred against

                   the order dated 25.09.2025 passed by the learned Exclusive

                   Special Judge-SC/ST Act-cum-District and Additional Sessions

                   Judge, Vaishali at Hajipur in A.B.P. No. 2585 of 2025 arising

                   out of Mahua P.S. Case No. 1015 of 2024 registered under

                   Sections 420, 147, 341, 342, 363, 323, 504, 506 of the IPC and

                   Section 3(1)(r), (s) (w) of SC/ST Act whereby and where under

                   the learned Court has rejected the anticipatory bail of the
Patna High Court CR. APP (SJ) No.4404 of 2025(3) dt.23-02-2026
                                             2/3




          appellant and the above noted case is pending in the Court of the

          learned Exclusive Special Judge-SC/ST Act-cum-District and

          Additional Sessions Judge, Vaishali at Hajipur.

                       3. As per allegation, the accused persons forcibly got

          registered a sale deed from the informant in respect of his house.

                       4. Learned counsel for the appellant has submitted

          that the appellant is innocent and has falsely been implicated in

          the present case. The FIR has been lodged after a period of eight

          months, without giving plausible reason for the delay. It is not

          possible for a person to get a sale-deed registered in his favour

          in registry office by putting coercion upon anyone.

                       5. Learned counsel for the informant vehemently

          opposed the prayer for anticipatory bail of the appellant and

          submitted that the appellant not only forcibly got registered a

          sale deed but also abused the informant in filthy words by

          calling his caste name.

                       6. There is no explanation of delay in lodging of the

          FIR after eight months of the occurrence. The allegation appears

          to be false.

                       7. Considering the above-mentioned facts and

          circumstance, the appeal is allowed and the impugned order

          dated 25.09.2025 passed by the learned Exclusive Special
             Patna High Court CR. APP (SJ) No.4404 of 2025(3) dt.23-02-2026
                                                          3/3




                       Judge-SC/ST Act-cum-District and Additional Sessions Judge,

                       Vaishali at Hajipur in A.B.P. No. 2585 of 2025 arising out of

                       Mahua P.S. Case No. 1015 of 2024, is set aside.

                                    8. Accordingly, let the appellant, in the event of his

                       arrest or surrender within four weeks before the learned court

                       below, be released on bail on furnishing bail bond of Rs.

                       10,000/- (Ten Thousand) with two sureties of the like amount

                       each to the satisfaction of the learned Exclusive Special Judge-

                       SC/ST Act-cum-District and Additional Sessions Judge, Vaishali

                       at Hajipur in connection Mahua P.S. Case No. 1015 of 2024.


                                            (Nawneet Kumar Pandey, J)

priyanka/-

U      T


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