Patna High Court

MANOJ KUMAR RAJAKversusTHE STATE OF BIHAR

Decided: 10 February 2026
Disposal: CONVERTED
Bench: ARUN KUMAR JHA

Holding

Only an appeal under Section 14A of the SC/ST (Prevention of Atrocities) Act is maintainable; a criminal revision petition is not permissible.

Summary

Manoj Kumar Rajak filed a criminal revision petition challenging the order of the Additional Sessions Judge‑I (Special Court) in Saharsa dated 18‑12‑2023, which had dismissed his complaint. The petitioner argued that the order should be appealed under Section 14A of the SC/ST (Prevention of Atrocities) Act rather than be subjected to a revision. The Patna High Court examined whether a revision petition is the correct remedy in such circumstances. The Court held that only an appeal under Section 14A is maintainable and a revision petition is not permissible. Consequently, the Court granted permission to convert the pending revision petition into an appeal and directed the petitioner’s counsel to effect the conversion within two weeks.

Issues considered

Whether a criminal revision petition is maintainable against the order of the Additional Sessions Judge rejecting a complaint under the SC/ST (Prevention of Atrocities) Act.
Whether the remedy available is an appeal under Section 14A of the SC/ST (Prevention of Atrocities) Act.

Legislation cited

SC/ST (Prevention of Atrocities) Act — s. 14A

Subjects

criminal revision
appeal
SC/ST Act
Section 14A
procedural law
conversion of petition

Judgment

                     IN THE HIGH COURT OF JUDICATURE AT PATNA
                                   CRIMINAL REVISION No.256 of 2024
                 Arising Out of PS. Case No.-1 Year-2023 Thana- SAHARSA COMPLAINT CASE District-
                                                         Saharsa
                 ======================================================
                 Manoj Kumar Rajak S/O Sri Mahavir Rajak, R/O Mohalla And P.O And P.S-
                 Sonbarsha, Distt.- Saharsa.
                                                                       ... ... Petitioner
                                               Versus
           1.     The State of Bihar.
           2.    Sanjay Sah S/O Khushilal Sah R/O M/S Soni Trading Company, Manori
                 Chowk, P.S- Sonbarsha Raj, Distt.- Sahasrsa.
           3.     Soni Devi W/O Sanjay Sah R/O M/S Soni Trading Company, Manori
                  Chowk, P.S- Sonbarsha Raj, Distt.- Sahasrsa.
                                                                ... ... Respondents
                 ======================================================
                 Appearance :
                 For the Petitioner/s   :       Mr. Anand Kishore Choudhary, Advocate
                 For the Respondent/s   :       Mr. Sadanand Paswan, Spl. P.P.
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE ARUN KUMAR JHA
                                       ORAL ORDER

3   10-02-2026                    Heard learned counsel for the parties.

                                  2. The present Criminal Revision petition has been

                   filed against the order dated 18.12.2023 passed by the learned

                   Additional Sessions Judge-I cum Special Court Schedule Caste /

                   Schedule Tribe, Saharsa in Complaint Case No. 1C of 2023, by

                   which the learned trial Court has rejected the Complaint petition

                   of the petitioner. Against such order, an appeal under Section

                   14A of the SC/ST (PoA) Act is only maintainable and not the

                   revision petition.

                                  3. In such circumstances, learned counsel for the

                   petitioner seeks permission to convert the present Criminal

                   Revision petition into an appeal.
          Patna High Court CR. REV. No.256 of 2024(3) dt.10-02-2026
                                                       2/2




                                    4. Permission, as prayed for, is accorded.

                                    5. Accordingly, learned counsel for the petitioner is

                    directed to convert the present Criminal Revision petition into

                    an appeal within two weeks.

                                    6. Office is directed to extend all cooperation in

                    this conversion.


                                                             (Arun Kumar Jha, J)

Shahnawaz/-

U     T

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