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Patna High Court

SAVITRI DEVI @ SAVITRI SINGHversusThe State of Bihar

Decided
Disposal
BAIL GRANTED

Holding

The court held that the dispute is primarily civil and the assault allegations are general, therefore granting bail to the petitioner.

Summary

The petitioner, Savitri Devi, sought bail in a criminal case (PS Case No. 219 of 2023) where she was accused of assault and other offences arising from a land dispute. The FIR alleged that she, along with co‑accused, assaulted the informant during a land measurement, with the land having been transferred from her husband to the informant. The petitioner argued that the dispute was essentially civil and that the assault allegations were vague and omnibus. The State opposed bail, but the informant’s counsel could not refute the petitioner’s factual submissions. Observing that the matter was primarily a civil dispute and the allegations were general, the court granted bail on a bond of Rs. 10,000 with two sureties, subject to Section 482(2) of the BNSS.

Issues considered

  • Whether bail should be granted to the petitioner despite charges under multiple IPC sections.
  • Whether the underlying land dispute renders the criminal allegations merely civil in nature.
  • Whether the allegations of assault are sufficiently specific to deny bail.

Legislation cited

Subjects

  • bail
  • civil dispute
  • land dispute
  • IPC offences
  • women
  • general allegation
  • Section 482
  • Patna High Court

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.65684 of 2024
                         Arising Out of PS. Case No.-219 Year-2023 Thana- MANER District- Patna
                 ======================================================
                 SAVITRI DEVI @ SAVITRI SINGH Wife of Sidh Kumar Singh, Resident of
                 Village - Tiwari Tola, Maner, P.S.- Maner, District – Patna. ... ... Petitioner/s
                                                     Versus
                 The State of Bihar.                                   ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :        Mr.Saurav Kumar Suman, Advocate
                                                   Mr. Braj Bhushan Mishra, Advocate
                 For the Opposite Party/s :        Mr.Narendra Kumar Singh, APP
                 For the Informant        :        Mr. Rikesh Singh, Advocate
                                                   Mr. Rakesh Kumar, Advocate
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE CHANDRA SHEKHAR JHA
                                       ORAL ORDER

3   03-02-2026                      Heard learned counsel appearing on behalf of the

                   petitioner, learned Additional Public Prosecutor appearing on

                   behalf of the State and learned counsel appearing for the

                   informant.

                                 2. The accused/petitioner apprehending her arrest in

                   connection with Maner P.S. Case No. 219 of 2023 registered for

                   the offences punishable under Sections 447, 341, 323, 354, 504,

                   506, 379 and 420 read with Section 34 of the Indian Penal Code.

                                 3. As per FIR, petitioner alleged to assault informant

                   alongwith other co-accused persons/family members, while some

                   dispute surfaced during measuring of land in issue, which was

                   purchased by the informant from one Ashok Kumar Singh, who

                   further purchased the land in issue from the husband of this

                   petitioner, namely, Sidh Kumar Singh.
Patna High Court CR. MISC. No.65684 of 2024(3) dt.03-02-2026
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                       4. It is submitted by learned counsel appearing on

          behalf of the petitioner that even the land in issue was not sold by

          this petitioner and for the simple reason as the land in issue once

          belongs to the husband of the petitioner, she was implicated with

          very much general and omnibus allegation qua physical assault. It

          is submitted that dispute primarily appears civil in nature.

                       5. Learned APP opposed the prayer of bail.

                       6. Learned counsel Mr. Rikesh Singh, appearing on

          behalf of the informant, while opposing the prayer of bail could not

          disputed the aforesaid factual submission as submitted by learned

          counsel appearing for the petitioner.

                       7. In view of aforesaid factual submissions and by

          taking note of fact as primarily dispute appears civil in nature,

          where the petitioner appears remotely connected with alleged land

          in issue coupled with the fact the allegation qua physical assault

          appears very much general and omnibus in nature, accordingly,

          above named petitioner, who is a lady, in the event of her arrest or

          surrender before the learned trial Court, within a period of four

          weeks of the order, is directed to be released on bail furnishing bail

          bond of Rs. 10,000/- (Rupees Ten Thousand) with two sureties of

          the like amount each to the satisfaction of the learned Additional

          Sessions Judge-V, Danapur/concerned Court, where the case is
              Patna High Court CR. MISC. No.65684 of 2024(3) dt.03-02-2026
                                                          3/3




                        pending in connection with Maner P.S. Case No. 219 of 2023

                        subject to the conditions as laid down under Section 482(2) of the

                        BNSS.



                                              (Chandra Shekhar Jha, J)
veena/-

U         T


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