Created by Fuzzy Cloud

Patna High Court

Satyanarayan Manjhi @ BabuajiversusThe State of Bihar

Decided
Disposal
REJECTED

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

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
                                            2/3




          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
                                                        3/3




                      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


Continue reading with your account

Sign in to read the full judgment. It’s free.

Sign in to read

Checking your session…

For a signed copy suitable for filing, refer to the court's website.