Patna High Court
Ranjit Kumar Singh @ Ranjit Singh @ Praveen Singh @ Praveen Kumar @ Satish Kumar @ Gorakh SinghversusThe State of Bihar
- Decided
- Disposal
- DISPOSED
- Bench
- RAJEEV RANJAN PRASAD
Holding
The Court held that the petitioner’s right to a speedy trial had been defeated and consequently granted bail.
Summary
The petitioner, Ranjit Kumar Singh, was charged under Sections 364(A), 120(B) and 212 of the IPC for kidnapping a businessman and was detained as an under‑trial prisoner since September 2014. Over eleven years, the trial progressed slowly, with only a fraction of the 59 prosecution witnesses examined and numerous delays due to petitions for evidence and seized items. The petitioner filed six bail applications, all of which were rejected by the trial court and the High Court on grounds of the seriousness of the offence and the expectation of a speedy trial. The State did not contest the claim that the petitioner had been in custody for 11 years and five months, and the petitioner had three criminal antecedents, two of which resulted in acquittal. The High Court held that the prolonged detention violated the constitutional right to a speedy trial and therefore ordered the release of the petitioner on bail, subject to a bond and sureties, and conditions under Section 480(3) of the Bhartiya Nagarik Suraksha Sanhita.
Issues considered
- Whether bail should be granted to an under‑trial prisoner who has been in custody for over eleven years despite the seriousness of the kidnapping charges.
- Whether the delay in trial violates the petitioner’s constitutional right to a speedy trial warranting bail.
Legislation cited
- Bhartiya Nagarik Suraksha Sanhita — s. 480(3)
- Indian Penal Code — s. 120(B), 212, 364(A)
Subjects
- kidnapping
- bail
- speedy trial
- under‑trial detention
- IPC
- constitutional law
- criminal procedure
Judgment
IN THE HIGH COURT OF JUDICATURE AT PATNA
CRIMINAL MISCELLANEOUS No.4531 of 2025
Arising Out of PS. Case No.-111 Year-2013 Thana- NAYAGAON District- Saran
======================================================
Ranjit Kumar Singh @ Ranjit Singh @ Ranjit Kumar @ Praveen Singh @
Praveen Kumar @ Satish Kumar @ Gorakh Singh, Son of Nagmani Singh,
R/O Vill- Chaturpur, P.S.-Nayagaon, District-Chhapra(Saran)
... ... Petitioner/s
Versus
The State of Bihar
... ... Opposite Party/s
======================================================
Appearance :
For the Petitioner/s : Mr.Anuj Kumar, Advocate
Mr. Shyam Kishore, Advocate
For the Opposite Party/s : Mr.Ahmad Ali, APP
======================================================
CORAM: HONOURABLE MR. JUSTICE RAJEEV RANJAN PRASAD
ORAL ORDER
4 26-02-2026 Heard learned counsel for the petitioner and learned
APP for the State.
2. This is the 6th attempt of the petitioner to obtain bail
in connection with Nayagaon P.S. Case No.111 of 2013
registered for the offences punishable under Sections
364(A)/120(B) and 212 of the Indian Penal Code (in short
‘IPC). The petitioner has got three criminal antecedents as stated
in paragraph ‘3’ of the application. He is in custody since
18.09.2014.
3. The allegation against the petitioner is to kidnap a
businessman, alongwith other co-accused persons, who was
released after payment of ransom money.
4. This Court having taken note of the seriousness of
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the allegations refused to grant regular bail to the petitioner on
earlier occasions with some hope that the trial would be
concluded within a reasonable period. In its order dated
06.12.2016, the then learned coordinate Bench of this Court
rejected the prayer of the petitioner considering the seriousness
of the allegations. In the order dated 31.01.2018, it is recorded
that up till now 19 prosecution witnesses including the victim,
father of the victim and I.O. have already examined and the case
is pending for receipt of material exhibits which have been
called for by the court on the prayer of the prosecution. The
learned coordinate Bench while rejecting the prayer of the
petitioner made it clear that if the trial of the petitioner is not
concluded within six months from the date of receipt/production
of a copy of the order, the petitioner may renew his prayer for
bail before the trial court itself.
5. Again when the petitioner did not get relief from
the trial court, he moved this Court in Cr.Misc.No.68008 of
2018 and this time vide order dated 23.01.2019, this Court
rejected the prayer after taking note of the information that now
23 prosecution witnesses out of 59 proposed prosecution
witnesses have already been examined. The learned trial court
was directed to expedite the trial of the petitioner and to
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conclude the same as early as possible.
6. Since then the petitioner has moved thrice and on
every occasion, this Court has noticed the number of witnesses
examined on behalf of the prosecution. In its order dated
05.08.2021, this Court recorded that out of 59 witnesses, 30
witnesses have been examined, meaning thereby that within a
period of two years seven months approximately from the date
of earlier rejection only 7 witnesses could be examined.
7. Subsequently, when this matter came before this
Court on 12.07.2023 in Cr.Misc.No.40519 of 2022, this Court
was informed that 34 witnesses have been examined, therefore,
within a period of two years from the date of last rejection only
four witnesses were examined. This Court still rejected the
prayer and this Court noticed the information of the learned trial
court saying that the trial is likely to be concluded within a
period of nine months.
8. This application has been filed on 23.01.2025. This
Court once again called for a report. The report available on the
record is completely vague as it does not give the number of
witnesses still required to be examined. The relevant part of the
report reads as under:-
“The present stage of trial of S.T. No.404/2015
is of prosecution evidence.
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The reason for delay in conclusion of trial is
multiple petitions filed by prosecution under
various provisions of the Evidence Act to call
for various documents and articles seized in
connection with the case and kept at different
authorities elsewhere such as vehicle in
Barachatti P.S. of Gaya District, gold
ornaments kept at Chutiya P.S. in Jharkhand,
seizure list in different P.S. and trial at Surat
and Daman. Other petitions for marking
exhibits many documents as bank-statements,
seizure list at different places.”
9. Learned APP for the State does not contest the
submission of learned counsel for the petitioner that as an
under-trial prisoner the petitioner has remained in jail for almost
11 years 5 months by now and there is no hope of his release in
near future. As regards the criminal antecedents of three cases,
he has been acquitted in two cases and in one of the cases he is
on bail.
10. In my considered opinion, keeping in view the
fact that the petitioner has already spent 11 years 5 months in
jail as an under-trial prisoner, his constitutional right of speedy
trial is being defeated, this is a fit case in which this Court must
direct release of the petitioner on bail. Let the petitioner be
released on bail on furnishing bail bond of Rs. 25,000/- (twenty
five thousand) with two sureties of the like amount each to the
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satisfaction of learned Additional District and Sessions Judge-
IV, Saran at Chapra in connection with Sessions Trial No.404 of
2015 arising out of Nayagaon P.S. Case No. 111 of 2013, subject
to the conditions as laid down under Section 480 (3) of the
Bhartiya Nagarik Suraksha Sanhita.
11. And further condition that the court below shall
verify the criminal antecedent of the petitioner and in case at
any stage it is found that the petitioner has concealed his
criminal antecedent, the court below shall take step for
cancellation of bail bond of the petitioner. However, the
acceptance of bail bonds in terms of the above-mentioned order
shall not be delayed for purpose of or in the name of
verification.
(Rajeev Ranjan Prasad, J)
arvind/-
U T
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