Patna High Court

Rabindra Prasad Singh @ Ravindra Prasad SinghversusThe State of Bihar

Decided: 21 January 2026
Disposal: BAIL GRANTED
Bench: PRABHAT KUMAR SINGH

Holding

The Court held that bail should be granted as the underlying dispute was resolved through mediation and the conditions of section 482(2) of the BNS were satisfied.

Summary

Rabindra Prasad Singh sought bail fearing arrest in a case registered under sections 316(2), 318(4) and 3(5) of the Bharatiya Nagarik Suraksha Sanhita (BNS) relating to a land‑sale dispute where the parties had taken consideration but refused to execute a sale deed. The dispute was earlier referred to a mediation centre by a coordinate bench of the Patna High Court (Cr. Misc. No. 55188 of 2025) and was resolved, as evidenced by annexures attached to the bail petition. The State opposed the bail application. The Court, noting the mediation settlement and the absence of any further adverse circumstances, ordered that the petitioner be released on bail upon furnishing a bond of Rs 10,000 with two sureties of equal amount, subject to the conditions of section 482(2) of the BNS. The order was made for a period of eight weeks from the date of the order. The bail petition was therefore disposed in favour of the petitioner.

Issues considered

Whether bail should be granted to the petitioner despite pending charges under sections 316(2), 318(4) and 3(5) of the BNS.
Whether the settlement of the underlying civil dispute through mediation influences the grant of bail.
Whether the conditions prescribed under section 482(2) of the BNS are satisfied.

Legislation cited

Bharatiya Nagarik Suraksha Sanhita — s. 316(2), 318(4), 3(5), 482(2)

Subjects

bail
mediation
land sale dispute
criminal procedure
BNS
section 482
section 316
section 318
section 3
Patna High Court

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                               CRIMINAL MISCELLANEOUS No.832 of 2026
                   Arising Out of PS. Case No.-174 Year-2025 Thana- PATRAKARNAGAR District- Patna
                 ======================================================
                 Rabindra Prasad Singh @ Ravindra Prasad Singh Son of Late Bhola Singh
                 Resident of LIG- 9/29, LIG Colony, P.S.- Patrakar Nagar, District- Patna

                                                                                ... ... Petitioner/s
                                                      Versus
                 The State of Bihar

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :      Mr. Niraj Kumar , Advocate
                 For the Opposite Party/s :      Mr. Anand Kishore Choudhary, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE PRABHAT KUMAR SINGH
                                       ORAL ORDER

2   21-01-2026                         Heard learned counsel for the petitioner and the

                   State .

                                2. Petitioner apprehends his arrest in a case registered

                   for the offence punishable under sections 316 ( 2 ), 318 ( 4 )

                   and 3 (5) of BNS.

                                3 . As per the FIR, all the accused persons including

                   this petitioner agreed to sell plot of land to informant, accepted

                   part consideration for the same but refused to register and

                   execute sale deed.

                                4. It is submitted on behalf of the petitioners that

                   pursuant to an order passed by Co-ordinate Bench of this

                   Hon’ble Court in Cr. Misc. No. 55188 of 2025 , the dispute was

                   referred to mediation center where both the parties appeared in

                   mediation proceedings along with advocates and the dispute was
            Patna High Court CR. MISC. No.832 of 2026(2) dt.21-01-2026
                                                        2/2




                      resolved between them, vide Annexure P/2 and P/3 to the bail

                      petition .

                                   5 . Learned counsel for the State opposed the bail

                      petition .

                                    6 Considering the aforesaid facts, and also the fact

                      that matter between both the parties has been resolved through

                      the process of mediation i. e ,. Annexure P /2 and P / 3 to the

                      bail petition and other circumstances of the case , in the event

                      of arrest or surrender within eight weeks from today, let the

                      petitioner, as named above, be enlarged on bail on furnishing

                      bail bond of Rs.10,000/-(ten thousand) with two sureties of the

                      like amount each to the satisfaction of the learned Judicial

                      Magistrate Patna , District- Patna in connection with Patrakar

                      Nagar P.S. Case No. 174 of 2025 , subject to the conditions laid

                      down under section 482(2) of the Bharatiya Nagarik Suraksha

                      Sanhita , 2023 .



                                            (Prabhat Kumar Singh, J)
Koushik/-

U      T

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