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Patna High Court

Rinki Kumari @ Parwati Kumari @ Rinki KodaversusThe State of Bihar

Decided
Disposal
DISMISSED

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

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


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