Patna High Court
Renu KumariversusThe State of Bihar
- Decided
- Disposal
- BAIL GRANTED
- Bench
- CHANDRA SHEKHAR JHA
Holding
The Court held that bail should be granted as the FIR does not contain specific allegations against the petitioner and she is not an authorized signatory.
Summary
The petitioner, Renu Kumari, a Self Help Group worker, was named in an FIR for alleged misappropriation of Rs.55,29,960 and failure to maintain accounts of eight SHGs, invoking Sections 409 and 420 of the IPC. She contended that she was a scapegoat, that the FIR lacked specific allegations, dates, times, and that she was not an authorized signatory for any withdrawals. The prosecution argued that her involvement was beyond suspicion, noting that a co‑accused, Kajal Kumari, had been granted anticipatory bail. The Court examined the deficiencies in the FIR and the lack of concrete evidence directly linking the petitioner to the alleged withdrawals. Relying on the principle that bail may be granted when the accusation is vague and the petitioner is not a primary suspect, the Court ordered her release on bail with a bond of Rs.10,000 and two sureties. The bail was conditioned under Section 438(2) of the CrPC and Section 482(2) of the Bhartiya Nagrik Suraksha Sanhita, 2023.
Issues considered
- Whether the petitioner is entitled to bail despite being named in the FIR under Sections 409 and 420 IPC.
- Whether the FIR's lack of specific details (date, time, authorized signatory) defeats the case for denial of bail.
- Whether the provisions of Section 438(2) CrPC and Section 482(2) BNSS 2023 are applicable to grant bail.
Legislation cited
- Bhartiya Nagrik Suraksha Sanhita, 2023 — s. 482(2)
- Code of Criminal Procedure — s. 438(2)
- Indian Penal Code — s. 409, 420
Subjects
- bail
- criminal breach of trust
- cheating
- Self Help Group
- misappropriation
- FIR deficiencies
- anticipatory bail
- BNSS 2023
Judgment
IN THE HIGH COURT OF JUDICATURE AT PATNA
CRIMINAL MISCELLANEOUS No.41771 of 2026
Arising Out of PS. Case No.-159 Year-2024 Thana- GORIAKOTHI District- Siwan
======================================================
Renu Kumari, D/o Rajbanshi Ray @ Rajbanshi Yadav, Resident of Village-
Chandauli, P.S.- Goreakothi, District- Siwan
... ... Petitioner
Versus
The State of Bihar
... ... Opposite Party
======================================================
Appearance :
For the Petitioner/s : Mr. Raju Prasad, Advocate
For the Opposite Party/s : Mr. Zainul Abedin, APP
======================================================
CORAM: HONOURABLE MR. JUSTICE CHANDRA SHEKHAR JHA
ORAL ORDER
2 30-06-2026 Heard learned counsel for the petitioner and
learned Additional Public Prosecutor for the State.
2. The accused/petitioner is named in the FIR and
apprehending her arrest in connection with Goreakothi P.S.
Case No.159 of 2024 registered under Sections 409 and
420 of the Indian Penal Code.
3. As per FIR, the petitioner was engaged as Self
Help Group (in short ‘SHG’) worker and allegedly she in
connivance with other workers, misappropriated an amount
of Rs.55,29,960/-. Petitioner had failed to maintain the
account register of 8 SHG out of 12 SHG and the alleged
irregularities happened during the period when she was
deployed therewith.
Patna High Court CR. MISC. No.41771 of 2026(2) dt.30-06-2026
2/3
4. It is submitted by learned counsel appearing
for petitioner that the petitioner was made scapegoat by the
higher officials, who were actually involved in
misappropriation of the alleged amount. It is submitted that
there is no specific allegation qua misappropriation is
available against this petitioner through FIR, moreover, the
FIR does not disclose the date and time of transaction. It is
submitted that admittedly petitioner was not an authorized
signatory of any of the withdrawals. Explaining criminal
antecedent, it is submitted that petitioner found involved in
one more criminal case, which is of different nature,
regarding domestic dispute, where she is on bail.
5. Learned APP while opposing the prayer of bail
submitted that the involvement of this petitioner was beyond
suspicion as alleged against other co-accused person like
Kajal Kumari, who has been granted anticipatory bail by one
of the learned co-ordinate Bench of this Court through Cr.
Misc. No.85314 of 2025 dated 18.12.2025.
6. In view of aforesaid factual submissions and by
taking note of fact as the allegation qua withdrawal is not
Patna High Court CR. MISC. No.41771 of 2026(2) dt.30-06-2026
3/3
specific against this petitioner, coupled with the fact that FIR
does not disclose any date and time of
transaction/occurrence, accordingly, the petitioner, above-
named, in the event of her arrest or surrender in the court
below within a period of four weeks from today, is directed
to be released on bail on furnishing bail bond of Rs.10,000/-
(Rupees Ten Thousand) with two sureties of the like amount
each to the satisfaction of the learned A.C.J.M.-VIII, Siwan
in connection with Goreakothi P.S. Case No.159 of 2024,
subject to the conditions as laid down under Section 438(2)
of the Code of Criminal Procedure (in short ‘CrPC’)/under
Section 482(2) of the Bhartiya Nagrik Suraksha Sanhita,
2023 (in short ‘BNSS’).
(Chandra Shekhar Jha, J.)
Sanjeet/-
U T
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