Patna High Court
Rinki Kumari @ Parwati Kumari @ Rinki KodaversusThe State of Bihar
- Decided
- Disposal
- DISMISSED
- Bench
- SANDEEP KUMAR
Holding
The High Court upheld the earlier order and denied bail to the petitioner.
Summary
The petitioner, Rinki Kumari, a self‑declared Naxal, was arrested on 19 June 2024 in connection with a 2017 case (PS Kajra No. 59) involving offences under Sections 121, 121A, 122 of the IPC, Sections 25(1‑b)A and 26 of the Arms Act, and several provisions of the UAPA. She applied for regular bail, claiming she was entitled to it, but the State opposed, highlighting her alleged active role in a Naxal group and other pending serious cases. The trial court had earlier rejected her bail application on 12 May 2025, noting her involvement in waging war against the State. On a second attempt, the Patna High Court examined whether there were any grounds to revisit the earlier order. Finding none, the Court upheld the earlier decision and denied bail, emphasizing the gravity of the charges and the petitioner’s alleged extremist activities.
Issues considered
- Whether the petitioner is entitled to regular bail despite being charged under serious offences of the IPC, Arms Act and UAPA.
- Whether the earlier bail denial can be reviewed on a second application.
Legislation cited
- Arms Act — s. 25(1-b)A, 26
- Indian Penal Code — s. 121, 121A, 122
- Unlawful Activities (Prevention) Act — s. 10, 13, 16, 18, 20, 23
Subjects
- bail
- Naxalism
- terrorism
- IPC
- Arms Act
- UAPA
- high court
Judgment
IN THE HIGH COURT OF JUDICATURE AT PATNA
CRIMINAL MISCELLANEOUS No.11596 of 2026
Arising Out of PS. Case No.-59 Year-2017 Thana- KAJRA District- Lakhisarai
======================================================
Rinki Kumari @ Parwati Kumari @ Rinki Koda D/O Budhu Koda R/O
Village- Kashi Tola, P.S- Kajra, Distt.- Lakhisarai
... ... Petitioner/s
Versus
The State of Bihar
... ... Opposite Party/s
======================================================
Appearance :
For the Petitioner/s : Mr. Mukesh Kumar
For the Opposite Party/s : Mr. Ganesh Prasad Singh
======================================================
CORAM: HONOURABLE MR. JUSTICE SANDEEP KUMAR
ORAL ORDER
2 23-02-2026 Heard the learned counsel for the petitioner and the
learned APP for the State.
2. This is the 2nd attempt of the petitioner. The
petitioner seeks bail in connection with Kajra P.S. Case No. 59
of 2017, registered for the offence under Sections 121, 121(A),
122 of the Indian Penal Code, under sections 25(1-b)A, 26 of
the Arms Act and u/s 10, 13, 16, 18, 20, 23 of the UAP Act.
3. Earlier the bail application of the petitioner was
rejected on 12.05.2025 in Cr. Misc. No. 18343 of 2025 which
reads as follows:-
“ Heard the learned counsel for
the petitioner and learned APP for the State.
2. The petitioner, who is in custody
since 19.06.2024, seeks regular bail in
connection with Kajra P.S. Case No. 59 of
2017 registered for the offence under
Patna High Court CR. MISC. No.11596 of 2026(2) dt.23-02-2026
2/2
Sections 121, 121(A), 122 of the Indian
Penal Code, under Sections 25(1-b)A, 26 of
the Arms Act and under Sections 10, 13, 16,
18, 20, 23 of the UAP Act.
3. The petitioner is a Naxal. She
has been named as a member of Dasta
(Group) by the arrested Naxal namely
Brihaspati Koda. The petitioner is accused
in two more cases of similar and serious
nature.
4. Considering the fact that the
petitioner is an active Naxal who is waging
war against the State, I am not inclined to
grant bail to the petitioner.
5. Accordingly, this application for
regular bail is hereby rejected.
4. This Court finds no ground to review its earlier
order. Accordingly, this application for regular bail stands
rejected.
(Sandeep Kumar, J)
Ranjeet/-
U T
Checking your session…