Patna High Court
Ravindra RaiversusThe State of Bihar
- Decided
- Disposal
- ALLOWED
- Bench
- NAWNEET KUMAR PANDEY
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
- Indian Penal Code — s. 147, 323, 341, 342, 363, 420, 504, 506
- Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 — s. 3(1)(r), 3(1)(s), 3(1)(w)
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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