Patna High Court
Devnandan Rai @ Deonandan RaiversusThe Union of India
- Decided
- Disposal
- DISPOSED
Holding
The petition is disposed as the University has already taken the necessary steps to address the financial irregularities.
Summary
The petitioner, Devnandan Rai, filed a public interest litigation seeking a court order directing the Vice Chancellor of Dr. Rajendra Prasad Central Agricultural University to lodge an FIR, recover misappropriated public funds, and compel a CBI inquiry into alleged financial irregularities under the Prevention of Corruption Act, 1988. The University, through its senior counsel, acknowledged that irregularities existed but asserted that appropriate remedial steps had already been taken. The court examined whether further judicial intervention was necessary given the University's claim of compliance. Finding no dispute that the University had acted on the irregularities, the court concluded that the petition did not warrant any additional orders. Consequently, the writ petition was disposed of without directing any further action.
Issues considered
- What relief, if any, should the court grant to compel the Vice Chancellor and other authorities to lodge an FIR and initiate a CBI inquiry into alleged financial irregularities?
- Whether the University’s claim of having already taken necessary steps negates the need for judicial intervention.
Legislation cited
- Prevention of Corruption Act, 1988 — s. 2(c)
Subjects
- public interest litigation
- financial irregularities
- misappropriation of funds
- Prevention of Corruption Act
- university governance
- CBI inquiry
- FIR
- writ petition
Judgment
IN THE HIGH COURT OF JUDICATURE AT PATNA
Civil Writ Jurisdiction Case No.1155 of 2026
======================================================
Devnandan Rai @ Deonandan Rai Son of Late Satya Narayan Rai, Resident
of Village and P.O.-Malikpur Via Dighra, District-Samastipur.
... ... Petitioner/s
Versus
1. The Union of India through the Secretary, DARE, Indian Council of
Agricultural Research, New Delhi.
2. The Union of India through Secretary, Ministry of Department of Personnel
and Training, Government of India.
3. The Secretary, Ministry of Home Department, Government of India.
4. The Director General of Police, Government of Bihar, Patna.
5. The Director, Central Bureau of Investigation, CGO Complex, Lodhi Road,
New Delhi.
6. The Visitor, Dr. Rajendra Prasad Central Agricultural University, Pusa,
District- Samastipur.
7. The Chancellor, Dr. Rajendra Prasad Central Agricultural University, Pusa,
District- Samastipur through its Registrar.
8. The Vice Chancellor, Dr. Rajendra Prasad Central Agricultural University,
Pusa, District- Samastipur.
9. The Comptroller, Dr. Rajendra Prasad Central Agricultural University, Pusa,
District- Samastipur.
10. The Secretary, Department of Agriculture and Research Education, New
Delhi.
11. The State of Bihar through the Agricultural Production Commissioner,
Agriculture Department, Govt. of Bihar, Patna.
12. The Agricultural Production Commissioner, Agriculture Department, Govt.
of Bihar, Patna.
... ... Respondent/s
======================================================
Appearance :
For the Petitioner/s : Mr.Vardaan Mangalam, Adv.
Mr. Dinu Kumar, Adv.
Ms. Ritika Rani, Adv.
For the UOI : Mr. Rana Vikram Singh, Dy. SGI
For RPAU : Mr. Abhinav Shrivastava, Sr. Adv.
Mr. Vijay Shankar Upadhyay, Adv.
======================================================
CORAM: HONOURABLE THE CHIEF JUSTICE
and
HONOURABLE MR. JUSTICE HARISH KUMAR
ORAL JUDGMENT
Patna High Court CWJC No.1155 of 2026 dt.16-02-2026
2/3
(Per: HONOURABLE THE CHIEF JUSTICE)
Date : 16-02-2026
This Public Interest Litigation has been filed by the
petitioner with the following prayer(s):
“(A) For commanding the Vice
Chancellor, Dr. Rajendra Prasad Central
Agricultural University, Pusa, District- Samastipur
and concerned authority to take legal action in
lodging FIR against the person concerned who
have been involved in committing financial
irregularities, misappropriation of fund which is
evident from the outcome of the enquiry approved
by the Hon'ble President-cum- Visitor, Dr.
Rajendra Prasad Central Agricultural University,
Pusa, District- Samastipur duly communicated to
the Secretary, DARE, Ministry of Agriculture and
Farmer Welfare vide President Secretariat ID No.
C III-07049/1/2022-CA-III dated 21.09.2023 as
contained in Annexure-P/3.
(B)For commanding the respondents
concerned specially the Vice Chancellor, Dr.
Rajendra Prasad Central Agricultural University,
Pusa, District- Samastipur to recover the public
money which has been misappropriated by the
person concerned which is evident from the report
dated 21.09.2023 as contained in Annexure-P/3 in
order to compensate the loss of the public money.
(C)Also for taking appropriate action
against concerned Vice Chancellor, Dr. Rajendra
Prasad Central Agricultural University, Pusa,
District- Samastipur who have failed to take
suitable action in lodging the Criminal case for
committing financial irregularity, misappropriation
and criminal misconduct defined under 2(c) of the
Prevention of Corruption Act, 1988 and
appropriate offences in order to ensure no one can
Patna High Court CWJC No.1155 of 2026 dt.16-02-2026
3/3
be unpunished for committing the crime which is
evident from Annexure P/2, P/3 & P/4.
(D) For issuance of direction to the
Director Central Bureau of Investigation, CGO
Complex Lodhi Road, New Delhi to enquire into
the matter with respect to financial irregularity,
defalcation misappropriation of public fund and
misuse of public money attracting offences under
section 2(c) of the Prevention of Corruption Act,
1988 and concerned section of BNS, 2023.”
2. Learned senior counsel appearing for Dr. Rajendra
Prasad Central Agricultural University, Pusa (in short
‘University’), on instruction, submitted that there is no dispute
that some financial irregularity was found; but for which
necessary steps have already been taken.
3. In view of such submission advanced by the learned
senior counsel appearing for the University, this writ petition
stands disposed of.
(Sangam Kumar Sahoo, CJ)
( Harish Kumar, J)
Anjani/-
AFR/NAFR N.A.
CAV DATE N.a.
Uploading Date 18 .02.2026
Transmission Date N.A.
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