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Patna High Court

Satan @ Satyanarayan Prasad @ Sat Narayan Singh @ Satan PrasadversusThe State of Bihar

Decided
Disposal
ALLOWED

Holding

The appeal is allowed; the trial court’s order denying bail is set aside and the appellant is released on bail.

Summary

The appellant, Satan @ Satyanarayan Prasad, was charged under several provisions of the Bharatiya Nyaya Sanhita, 2023 and the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act for allegedly assaulting an informant and her family with deadly weapons and using caste‑based slurs. The trial court rejected his bail application, holding that the offences were cognizable and serious. On appeal, the appellant contended that he was falsely implicated due to a land dispute, that the FIR was lodged five days after the incident and was vague, and that no caste slur was uttered in public. The State and the informant opposed bail, insisting that the allegations under the SC/ST Act were prima facie established. The Patna High Court, after considering the delay, the lack of prior criminal record and the appellant’s claim of false implication, set aside the trial court’s order and granted bail on condition of a Rs. 15,000 bond with two sureties. The appeal was therefore allowed and the appellant released on bail.

Issues considered

  • Whether bail should be granted to the accused in a case involving offences under the Bharatiya Nyaya Sanhita and the SC/ST Act.
  • Whether the allegations of caste‑based slurs and assault under the SC/ST Act are sufficiently substantiated.
  • Whether the five‑day delay in lodging the FIR and the alleged vagueness of the complaint affect the bail decision.

Legislation cited

Subjects

  • bail
  • SC/ST Act
  • assault
  • caste discrimination
  • false implication
  • criminal procedure

Judgment

                     IN THE HIGH COURT OF JUDICATURE AT PATNA
                                  CRIMINAL APPEAL (SJ) No.4839 of 2025
                        Arising Out of PS. Case No.-59 Year-2025 Thana- SC/ST District- Gopalganj
                 ======================================================
                 Satan @ Satyanarayan Prasad @ Sat Narayan Singh @ Satan Prasad S/O-
                 Late Gajadhar Prasad Resident of Village- Konhwa, P.S- Gopalganj, Distt.-
                 Gopalganj, At present Resident of Village- House no. 6417/ A, Sector 56,
                 P.S.- Chandigarh, Distt.- Chandigarh.

                                                                                    ... ... Appellant/s
                                                        Versus
           1.    The State of Bihar
           2.    Prabhawti Devi W/O Prabhu Sah R/O Village- Konhwa, P.S- Gopalganj,
                 Distt.- Gopalganj.

                                                           ... ... Respondent/s
                 ======================================================
                 Appearance :
                 For the Appellant/s      :        Mr. Pankaj Kumar Dubey, Advocate
                 For the Respondent/s     :        Mr. Sadanand Paswan, SPP
                 For the O.P. No. 2       :        Mr. Vyas Kumar Mishra, Advocate
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE RUDRA PRAKASH
                 MISHRA
                                       ORAL ORDER

3   12-03-2026                       Heard learned counsel for the appellant, learned

                   Special Public Prosecutor for the State, learned counsel for the

                   informant/Respondent No. 2 and perused the case diary.

                                2. The instant appeal has been filed by the appellant

                   against the order dated 11.11.2025 passed by learned Additional

                   Sessions Judge XI-cum-Special Judge SC/ST, Gopalganj

                   whereby the prayer for bail of the appellant in connection with

                   Gopalganj SC/ST P.S. Case No. 59 of 2025 under Sections

                   126(2), 115(2), 118(1), 109, 303(2), 351(2), 352, 3(5) of the

                   Bharatiya Nyaya Sanhita, 2023, read with Sections 3(1)(r), 3(1)

                   (s) and 3(2)(va) of SC/ST Act was rejected.
Patna High Court CR. APP (SJ) No.4839 of 2025(3) dt.12-03-2026
                                             2/3




                       3. Prosecution case, in short, is that the appellant

          along with co-accused persons assaulted the informant and her

          family members by means of deadly weapons and abused them

          with caste based slurs.

                       4. Learned counsel for the appellant submits that the

          appellant is innocent and has falsely been implicated in the

          present case. Charge-sheet has been submitted in this case.

          Learned counsel for the appellant also submits that there is

          delay of five days in lodging the FIR. As per FIR, the allegation

          levelled against the appellant is of assaulting the informant by

          means of iron rod due to which she sustained injury on thumb of

          right hand and the same is not specific rather general and

          omnibus in nature. It is next submitted that the appellant has

          been falsely implicated in this case due to land dispute between

          the parties. Learned counsel for the appellant further submits

          that the appellant has not taken the caste name of the informant

          in public view. Hence, no offence under the provisions of SC/ST

          Act is made out against him. The appellant has no intention to

          disgrace the image of the informant in public view. The

          appellant is in custody since 19.10.2025 and has got no criminal

          antecedent.

                       5. Learned Special P.P. for the State and the informant
             Patna High Court CR. APP (SJ) No.4839 of 2025(3) dt.12-03-2026
                                                          3/3




                       have vehemently opposed the prayer for grant of bail to the

                       appellant.

                                    6. Considering the aforesaid facts and circumstances

                       of the case and the period of custody undergone by the

                       appellant, this Court is inclined to allow this appeal.

                       Accordingly, the appeal is allowed and order dated 11.11.2025

                       passed by learned Additional Sessions Judge XI-cum-Special

                       Judge SC/ST, Gopalganj is hereby set aside.

                                    7. Let the appellant be released on bail on furnishing

                       bail bonds of Rs. 15,000/- (Rupees Fifteen thousand) with two

                       sureties of the like amount each to the satisfaction of Court

                       below/concerned Court in connection with Gopalganj SC/ST

                       P.S. Case No. 59 of 2025.



                                                                    (Rudra Prakash Mishra, J)
Rajorshi/-

U       T


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