Patna High Court
Satyanarayan Manjhi @ BabuajiversusThe State of Bihar
- Decided
- Disposal
- REJECTED
- Bench
- SONI SHRIVASTAVA
Holding
The court denied bail to the petitioner.
Summary
Satyanarayan Manjhi was arrested on charges of forceful sexual intercourse, recording a video, and related offences under the Bharatiya Nyaya Sanhita, the POCSO Act and the IT Act. The petitioner argued that the FIR was lodged four days after the alleged incident without explanation, claiming false implication due to village enmity and highlighting his clean record. The State and the co‑accused’s counsel countered that the allegations were specific and supported by the victim’s statement recorded under sections 180 and 183 of the BNSS. The court considered the seriousness of the offences, the victim’s age, and the victim’s recorded statement, and found no sufficient ground to grant bail. Consequently, the bail petition was rejected and the trial court was directed to expedite the proceedings.
Issues considered
- Whether bail should be granted to the accused given the seriousness of the sexual offences and the victim’s age.
- Whether the delay in filing the FIR and the claim of false implication affect the bail eligibility.
Legislation cited
- Bharatiya Nyaya Sanhita — s. 115(2), 126(2), 180, 183, 3(5), 70(2)
- Information Technology Act — s. 67A, 67B
- POCSO Act — s. 6
Subjects
- bail
- sexual offences
- POCSO
- delay in FIR
- victim statement
- IT Act
- Bharatiya Nyaya Sanhita
- false implication
Judgment
IN THE HIGH COURT OF JUDICATURE AT PATNA
CRIMINAL MISCELLANEOUS No.51300 of 2025
Arising Out of PS. Case No.-51 Year-2025 Thana- MANJHI District- Saran
======================================================
Satyanarayan Manjhi @ Babuaji S/o Chizhu Manjhi RO Village- Jaitiya, PS-
Manjhi, District- Saran
... ... Petitioner/s
Versus
1. The State of Bihar
2. Pinki Kumari D/o Raju Ram R/o vill - Jaitiya, P.S.- Manjhi, Distt.- Saran
... ... Opposite Party/s
======================================================
Appearance :
For the Petitioner : Ms. Chetna, Advocate
For the State : Mr. Bhanu Pratap Singh, APP
For the O.P. No.2 : Mr. Ajay Kumar Pandey, Advocate
Mrs. Shyama Rani, Advocate
======================================================
CORAM: HONOURABLE JUSTICE SMT. SONI SHRIVASTAVA
ORAL ORDER
7 11-02-2026 Heard learned counsel for the petitioner, learned
counsel for the opposite party no.2 and learned APP for the
State.
2. The petitioner seeks bail in a case registered for
the offence punishable under Sections 126(2), 115 (2), 70(2) and
3(5) of the Bharatiya Nyaya Sanhita, Section 6 of the POCSO
Act and Section 67A and 67B of the IT Act.
3. As per the prosecution case, the allegation in
the F.I.R. is that the petitioner along with two other co-accused
has made forceful sexual relation with the informant and also
made video.
4. It is submitted by learned counsel for the
Patna High Court CR. MISC. No.51300 of 2025(7) dt.11-02-2026
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petitioner that the present F.I.R. has been lodged after a delay of
four days inasmuch as the occurrence is said to have taken place
on 08.02.2025, while the F.I.R. was lodged on 12.02.2025,
without tendering any plausible explanation. It is further
submitted that the petitioner has been falsely implicated in this
case due to previous enmity as both the parties are residents of
the same village. Further, the entire story of Ashish Kumar
being assaulted and sent away and then the act of rape
committed, appears to be not believable. The petitioner has no
criminal antecedent and has been languishing in custody since
14.02.2025.
5. Learned APP for the State and learned counsel
for the opposite party no.2 vehemently opposing the bail
petition submitted that the allegations are direct and specific
against this petitioner and this petitioner and one Dinesh Sah
had forcefully made relationship with the victim, which fact
stands supported by the statement of the victim recorded under
Section 180 and 183 of the BNSS during course of
investigation.
6. Taking into consideration facts and circumstance
of the case, the seriousness of the allegation as also the age and
the statement of the victim, I am not inclined to enlarge the
Patna High Court CR. MISC. No.51300 of 2025(7) dt.11-02-2026
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petitioner on bail. The prayer for bail is hereby rejected.
However, the learned Trial Court is directed to proceed with the
case expeditiously keeping in mind that the present case is one
under the provisions of the POCSO Act.
(Soni Shrivastava, J)
Trivedi/-
U T
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