Patna High Court

MANISH RANJANversusTHE STATE OF BIHAR

Decided: 17 March 2026
Disposal: CONVERTED
Bench: PRAVEEN KUMAR

Holding

An appeal under Section 14A(1) of the SC/ST Act lies and the petition must be converted into a criminal appeal (Special Judge).

Summary

Manish Ranjan filed a petition challenging cognizance taken against him under Sections 3(1)(r)(s) and 3(2)(va) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act. The trial court’s order indicated that an appeal under Section 14A(1) of the same Act was available, requiring the petition to be converted into a criminal appeal (Special Judge). The High Court examined whether the procedural requirement of conversion was mandatory. It held that, since an appeal under Section 14A(1) lies, the petition must be re‑filed as a criminal appeal before the Special Judge. Consequently, the Court granted the petitioner four weeks to effect the conversion and disposed of the original application.

Issues considered

Whether an appeal under Section 14A(1) of the SC/ST (Prevention of Atrocities) Act is available against the order taking cognizance.
Whether the petition must be converted into a criminal appeal (Special Judge) as a matter of law.

Legislation cited

Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act — s. 14A(1), 3(1)(r), 3(1)(s), 3(2)(va)

Subjects

SC/ST Act
Section 14A
Criminal appeal
Special Judge
Conversion of petition
Atrocities

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.16111 of 2024
                    Arising Out of PS. Case No.-218 Year-2021 Thana- BHAGWANPUR District- Vaishali
                 ======================================================
                 MANISH RANJAN                                  ... ... Petitioner
                                          Versus
                 THE STATE OF BIHAR                    ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :       Mr.Vasant Vikas
                 For the Opposite Party/s :       Mrs.Usha Kumari 1
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE PRAVEEN KUMAR
                                       ORAL ORDER

2   17-03-2026                    Heard learned counsel for the petitioner and learned
                   counsel for the State.
                                2. It appears from the impugned order that the learned
                   court below has taken cognizance against the petitioner under
                   Sections 3(1)(r)(s), 3(2)(va) of the Scheduled Castes and
                   Scheduled Tribes (Prevention of Atrocities) Act, against which
                   an appeal under Section 14A(1) of the SC/ST Act would lie and
                   as such this application is required to be converted into one as
                   Cr. Appeal (SJ).
                                3. In view of the above, four weeks’ time is granted to
                   the petitioner to convert this application into one as Cr. Appeal
                   (SJ).
                                4. This application stands disposed of.



                                              (Praveen Kumar, J)
Pawan/-

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