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Patna High Court

Briksh Manjhi @ Rambriksh ManjhiversusThe State of Bihar

Decided
Disposal
ALLOWED

Holding

The appeal is allowed and the order rejecting bail is set aside, directing that bail be granted to the appellants.

Summary

The appellants, Briksh Manjhi and Sukhdeo Manjhi, were charged under multiple sections of the Bihar National Security Act, 2023 and the SC/ST (Prevention of Atrocities) Act for alleged assault, robbery and caste-based humiliation. The Special Judge had rejected their bail application, prompting an appeal to the Patna High Court. The appellants argued that the FIR contained only a vague, omnibus allegation and that they had no prior criminal record, contending they were falsely implicated. The State opposed bail, citing the seriousness of the charges. The High Court, noting the lack of specific allegations and the general nature of the FIR, allowed the appeal, set aside the lower court’s order, and directed that bail be granted upon furnishing a bond with sureties. Consequently, the appellants were released on bail pending trial.

Issues considered

  • Whether the appellants are entitled to bail despite being charged under multiple serious provisions of the Bihar National Security Act and the SC/ST (PoA) Act.
  • Whether the allegations in the FIR are sufficiently specific to justify denial of bail.

Legislation cited

Subjects

  • bail
  • general and omnibus allegation
  • SC/ST Act
  • Bihar National Security Act
  • criminal procedure
  • false implication

Judgment

                     IN THE HIGH COURT OF JUDICATURE AT PATNA
                                  CRIMINAL APPEAL (SJ) No.4932 of 2025
                       Arising Out of PS. Case No.-172 Year-2024 Thana- TANKUPPA District- Gaya
                 ======================================================
           1.     Briksh Manjhi @ Rambriksh Manjhi S/o- Nanhak Manjhi Village- Nanhak
                  Chak PS- Tenkuppa Dist- Gaya
           2.    Sukhdeo Manjhi S/o- Nanhak Manjhi Village- Nanhak Chak PS- Tenkuppa
                 Dist- Gaya

                                                                                  ... ... Appellant/s
                                                       Versus
           1.    The State of Bihar
           2.    Raj Kumar S/o- Ruplal Paswan R/v- Jehali Bigha Ps- Tankuppa Dist- Gaya

                                                           ... ... Respondent/s
                 ======================================================
                 Appearance :
                 For the Appellant/s     :        Mr. Ajay Kumar Sinha, Advocate.
                 For the Respondent/s    :        Mr. Binay Krishna, Spl. P.P.
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE ASHOK KUMAR PANDEY
                                       ORAL ORDER

5   14-05-2026                 Heard learned counsel for the appellants and learned

                   Special Public Prosecutor for the State.

                               2. The instant appeal has been filed by the appellants

                   against the order dated 04.11.2025 passed by learned Exclusive

                   Special Judge, SC/ST, Gaya Ji whereby the prayer for bail of the

                   appellant in connection with CIS No. 3743 OF 2025 arising out

                   of Tankuppa P.S. Case No. 172 of 2024 under Sections 192(2),

                   191(3), 190, 126(2), 115, 117(2), 109, 352, 351(2) of the B.N.S.,

                   2023 and sections 3(1)(r), 3(1)(s) of SC/ST (PoA) Act was

                   rejected.

                               3. The case of the respondent, in short, is that the

                   appellants, along with others, arrived armed with lathi, danda,
Patna High Court CR. APP (SJ) No.4932 of 2025(5) dt.14-05-2026
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          and khanti, and started assaulting the respondent and others. It is

          further alleged that a motorcycle and a gold chain were

          snatched, and the uncle of the respondent was also assaulted.

                       4. It is submitted by learned counsel for the appellants

          that appellants have been falsely implicated in this case. He also

          submits that from perusal of the FIR, it is clear that the nature of

          the allegation is general and omnibus. As far as humiliating the

          respondent with caste name is concerned, there is no such

          allegation in the FIR. He further submits that the appellant has

          got no criminal antecedent and they are languishing in judicial

          custody since 08.10.2025.

                       5. The appeal for bail is opposed by learned Spl. P.P.

          for the State and learned counsel for the informant.

                       6. Having heard learned counsel for the parties and

          taking into consideration that there is general and omnibus

          allegation against the appellants, the Court is inclined to allow

          this appeal. Accordingly, the appeal is allowed and the

          impugned order dated 04.11.2025 is hereby set aside.

                       7. The appellants are directed to be enlarged on bail in

          connection with Tankuppa P.S. Case No. 172 of 2024 on

          furnishing bail bond of Rs. 10,000/- (Rs. ten thousand only)

          each with two sureties of the like amount each to the satisfaction
           Patna High Court CR. APP (SJ) No.4932 of 2025(5) dt.14-05-2026
                                                        3/3




                     of the learned Exclusive Special Judge, SC/ST Act, Gaya.


                                                    (Ashok Kumar Pandey, J)
Sudhanshu/-

U      T


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