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Patna High Court

Satyam KumarversusThe State of Bihar

Decided
Disposal
CONVERTED

Holding

The High Court permitted the conversion of the criminal revision petition into an appeal under Section 101(5) of the Juvenile Justice Act.

Summary

The petitioner, Satyam Kumar, filed a criminal revision petition challenging an order dated 27-02-2026 passed by the Additional Sessions Judge‑I (Special Judge, Children Court), Bhagalpur, in Special Case (Children) No. 15 of 2025. The petitioner sought to have the revision petition converted into an appeal under Section 101(5) of the Juvenile Justice (Care and Protection of Children) Act, which allows an appeal to the High Court following the procedure of the Code of Criminal Procedure, 1973. The learned counsel for the petitioner requested permission for this conversion, and the High Court examined whether such a procedural transformation was permissible. The Court held that the conversion was within the scope of Section 101(5) and granted the petitioner's request. Consequently, the Court directed that the conversion be effected within two weeks and that the converted petition be listed before the appropriate Bench.

Issues considered

  • Whether a criminal revision petition can be converted into an appeal under Section 101(5) of the Juvenile Justice (Care and Protection of Children) Act
  • Whether the High Court has jurisdiction to entertain such a conversion

Legislation cited

Subjects

  • Juvenile Justice
  • Criminal Revision
  • Appeal Conversion
  • Section 101(5)
  • High Court Procedure

Judgment

                     IN THE HIGH COURT OF JUDICATURE AT PATNA
                                    CRIMINAL REVISION No.473 of 2026
                     Arising Out of PS. Case No.-141 Year-2025 Thana- Bhawanipur District- Bhagalpur
                 ======================================================
                 Satyam Kumar

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

                                                           ... ... Respondent/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :        Mr. Prem Kumar, Advocate
                 For the Respondent/s     :        Mr. Tarkeshwar Nath Thakur, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE ARUN KUMAR JHA
                                       ORAL ORDER

2   30-06-2026                  Present revision petition has been filed for setting

                   aside the order dated 27.02.2026 passed by the learned

                   Additional Sessions Judge-I-cum-Special Judge (Children

                   Court), Bhagalpur in Special Case (Children) No. 15 of 2025.

                                2. Now, Section 101(5) of the Juvenile Justice (Care

                   and Protection of Children) Act provides for filing an appeal

                   before the High Court in accordance with the procedure

                   specified in the Code of Criminal Procedure, 1973 against the

                   order of the Children’s Court.

                                3. Faced with the situation, learned counsel for the

                   petitioner seeks permission to convert the instant criminal

                   revision petition into an appeal under Section 101(5) of JJ Act.

                                4. Permission is accorded.

                                5. Learned counsel for the petitioner is permitted to
           Patna High Court CR. REV. No.473 of 2026(2) dt.30-06-2026
                                                        2/2




                     convert the present criminal revision petition into an appeal

                     under Section 101(5) of JJ Act within two weeks.

                                  6. The office is directed to extend all co-operation to

                     the learned counsel for the petitioner towards conversion.

                                  7. As soon as the petitioner takes step for conversion

                     of the petition, the converted petition be listed before the

                     appropriate Bench.



                                                       (Arun Kumar Jha, J)
Ashish/-

U


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