Patna High Court
Satan @ Satyanarayan Prasad @ Sat Narayan Singh @ Satan PrasadversusThe State of Bihar
- Decided
- Disposal
- ALLOWED
- Bench
- R P MISHRA
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
- Bharatiya Nyaya Sanhita, 2023 — s. 109, 115(2), 118(1), 126(2), 303(2), 3(5), 351(2), 352
- Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act — s. 3(1)(r), 3(1)(s), 3(2)(va)
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/-
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