Patna High Court
Niharika RanjanversusThe State of Bihar
- Decided
- Disposal
- BAIL GRANTED
- Bench
- PRABHAT KUMAR SINGH
Holding
The Court granted bail to the petitioner, subject to a bond and sureties, finding insufficient material to justify continued detention.
Summary
The petitioner, Niharika Ranjan, a former administrator of Sagyan Educational Research Charitable Trust, was charged under sections 318(4) and 316(5) of the Bhartiya Nyaya Sanhita for allegedly retaining cheque books, key documents and financial records after leaving her post. She contended that the allegations were based solely on oral statements without any specific or authentic evidence, and she had already denied the claims in a legal notice dated 03‑07‑2025. The petitioner highlighted her clean antecedent and argued that the case was a retaliatory measure linked to a dispute over unpaid salary and expenses. The State opposed the bail application, asserting the seriousness of the offences. Considering the lack of concrete evidence, the petitioner’s clean record, and the circumstances, the Court granted bail on a bond of Rs.10,000 with two sureties, subject to conditions under section 482(2) of the Bharatiya Nagarik Suraksha Sanhita, 2023.
Issues considered
- Whether the petitioner is entitled to bail despite the charges under sections 318(4) and 316(5) of the Bhartiya Nyaya Sanhita.
- Whether the material on record is sufficient to justify the petitioner’s arrest.
- Whether the conditions prescribed under section 482(2) of the Bharatiya Nagarik Suraksha Sanhita, 2023, are applicable.
Legislation cited
- Bharatiya Nagarik Suraksha Sanhita, 2023 — s. 482(2)
- Bhartiya Nyaya Sanhita — s. 316(5), 318(4)
Subjects
- bail
- criminal procedure
- misappropriation
- trust administration
- clean antecedent
- sections 318
- section 316
- section 482
- Indian criminal law
Judgment
IN THE HIGH COURT OF JUDICATURE AT PATNA
CRIMINAL MISCELLANEOUS No.30090 of 2026
Arising Out of PS. Case No.-55 Year-2026 Thana- GANDHIMAIDAN District- Patna
======================================================
Niharika Ranjan D/O Lalan Prasad R/O Flat No.- 304, 3rd Floor, Brahmlok
Apartment, Opposite HDFC Bank P.S. Rupaspur, Town and District
Patna,PIn- 801503
... ... Petitioner/s
Versus
The State of Bihar Bihar, Patna
... ... Opposite Party/s
======================================================
Appearance :
For the Petitioner/s : Mr. Rajesh Kumar Dubey
For the Opposite Party/s : Mr. Navin Kumar Pandey
======================================================
CORAM: HONOURABLE MR. JUSTICE PRABHAT KUMAR SINGH
ORAL ORDER
2 11-05-2026 Heard learned counsel for the petitioner and the
State .
2. Petitioner apprehends his arrest in a case registered
for the offence punishable under sections 318(4) and 316(5) of
Bhartiya Nyaya Sanhita.
3 . Informant alleged that this petitioner, while serving
as an administrator at Sagyan Educational Research Charitable
Trust, held custody of the institution's cheque books, key
documents, and financial records. It is further alleged that on
February 24, 2025, she vacated her position without returning
these items. Despite subsequent requests, she has failed to
surrender the records, resulting in financial and operational
losses for the institution .
Patna High Court CR. MISC. No.30090 of 2026(2) dt.11-05-2026
2/3
4. It is submitted on behalf of the petitioners that
petitioner is quiet innocent and has committed no offence as
alleged. As a matter of fact, informant has only made oral
allegation against this petitioner and has not given any specific
and authentic information, evidence as well as detail regarding
the transaction that on which date and what amounts were
transferred/obtained by this petitioner and as such, it is
impossible to establish that petitioner has misappropriated any
amount. It is further submitted that petitioner has already replied
to legal notice of informant on 03.07.2025 in which she has
categorically denied the entire allegation against her. In fact,
when petitioner raised the issue of non-payment of salary and
reimbursement of official expenses during her working period
from December 2024 to February 2025, this false and concocted
case has been lodged against her by the informant. Petitioner is
lady and claims clean antecedent.
5 . Learned counsel for the State opposed the bail
petition .
6 Considering the aforesaid facts, materials available
on record, clean antecedent of the petitioner and other
circumstances of the case , in the event of arrest or surrender
within eight weeks from today, let the petitioner, as named
Patna High Court CR. MISC. No.30090 of 2026(2) dt.11-05-2026
3/3
above, be enlarged on bail on furnishing bail bond of
Rs.10,000/-(ten thousand) with two sureties of the like amount
each to the satisfaction of the learned S.D.J.M. Patna in
connection with Gandhi Maidan P.S. Case No. 55 of 2026 ,
subject to the conditions laid down under section 482(2) of the
Bharatiya Nagarik Suraksha Sanhita , 2023 .
(Prabhat Kumar Singh, J)
Koushik/-
U T
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