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Patna High Court

Jayachandra Yadav alias Jaichandra YadawversusThe State of Bihar

Decided
Disposal
DISPOSED

Holding

The Court directed the petitioner to produce the vehicle and required documents before the registration authority, which must then renew the registration within four weeks.

Summary

The petitioner, Jayachandra Yadav, filed a writ petition seeking a mandamus directing the District Transport Officer, Motihari, to renew the registration of his vehicle (BR05P-3600) which had expired on 11‑04‑2025. He alleged that the authorities were refusing renewal and that the required documents were misplaced, preventing him from producing them. The respondents contended that the petitioner must furnish Form 21, Form 22, the invoice, and the original registration certificate, and that renewal can only proceed after physical verification of the vehicle. The Court held that the petitioner must produce the vehicle along with the requisite documents before the registration office, after which the authority must complete the renewal within four weeks. Accordingly, the Court directed the petitioner to comply and ordered the respondent to process the renewal expeditiously, disposing of the writ petition.

Issues considered

  • What procedural requirements must the petitioner satisfy for renewal of vehicle registration under the applicable motor vehicle regulations?
  • Can the High Court issue a mandamus directing renewal of registration without the petitioner first producing the statutory documents?

Subjects

  • vehicle registration renewal
  • mandamus
  • Transport Department
  • Motor Vehicles Act
  • procedural compliance
  • writ jurisdiction

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                               Civil Writ Jurisdiction Case No.19453 of 2025
                 ======================================================
                 Jayachandra Yadav alias Jaichandra Yadaw, Son of Kunal Yadav, resident of
                 village Pokhara, Talwa, Police Station Kotwa, District- East Champaran at
                 Motihari.

                                                                          ... ... Petitioner/s
                                                  Versus
           1.    The State of Bihar through the Principal Secretary, Transport Department,
                 Government of Bihar, Patna.
           2.    The District Transport Officer, Motihari.

                                                           ... ... Respondent/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s    :      Mr. Suresh Mukhiya, Advocate.
                 For the Respondent/s    :      Mr. Anant Pd. Singh, SC 15 with
                                                Ms. Deepika Sharma, AC to SC 15.
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE A. ABHISHEK REDDY
                                    ORAL ORDER

5   10-03-2026                   Heard the learned counsel for the parties.

                                 2. The present Writ Petition has been filed for the

                   following reliefs:-

                                                         “……..for           issuance         of
                                              writ/writs,              direction/directions,
                                              order/orders including a writ in the
                                              nature    of   Mandamus           directing   the
                                              Respondent No. 2 to renew the certificate
                                              of registration of vehicle of the petitioner
                                              being Registration No. BR05P-3600
                                              registered in the office of District
                                              Transport Officer, Motihari bearing class
                                              of Vehicle LMV, Bolero SCX, Chassis No.
                                              MAIPS2GAKA 5B-65019, Engine No.
Patna High Court CWJC No.19453 of 2025(5) dt.10-03-2026
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                                      GAA4B, 28378 which was initially
                                      registered on 12.04.2010 and the date of
                                      expiry is 11.04.2025.”
                      3. Learned counsel appearing on behalf of the

          petitioner submits that the petitioner has sought renewal of the

          registration of the vehicle bearing Registration No. BR05P-3600

          with Chassis No. MAIPS2GAKA5B-65019, Engine No.

          GAA4B, 28378, however, the authorities have not being

          renewing the registration of the vehicle of the petitioner on one

          pretext or the other. Learned counsel submits that the

          respondent-authorities may be directed to renew the registration

          of the vehicle of the petitioner. Learned counsel further submits

          that the documents relating to the vehicle are misplaced so the

          petitioner is unable to produce the same before the authority and

          seeks a direction from this Court to direct the respondent-

          authorities to renew the registration of the vehicle of the

          petitioner bearing Registration No. BR05P-3600.

                        4. In the counter-affidavit field by the respondent-

          authorities, the authorities has taken stand that the petitioner is

          obligated to produce Form 21 and Form 22 showing the details

          of the ownership and also the details of the vehicle through

          online mode. The counter-affidavit further states that as per the

          Standard Operating Procedure for backlog entry of registered
Patna High Court CWJC No.19453 of 2025(5) dt.10-03-2026
                                           3/4




          vehicles, the owner of the vehicle is obligated to produce the

          following documents:-

                        (i)    Form      21      (Sale    letter   issued   by   the
                                dealer/manufacture).
                        (ii) Form 22 (road worthiness certificate issued by
                                the Manufacturer).
                        (iii) Invoice of manufacture/dealer and
                        (iv)    Certificate of issuance submitted at the time of
                                first registration.
                      and in absence of the same, the papers will be

          provided to the petitioner after physical verification of the

          vehicle by the concerned registration office. The authority will

          take necessary action for renewing the registration of the vehicle

          of the petitioner.

                      5. Having regard to the averments made in the

          counter-affidavit filed by the respondent-authorities, the

          petitioner is directed to produce the vehicle bearing Registration

          No. BR05P-3600 with Chassis No. MAIPS2GAKA5B-65019,

          Engine No. GAA4B, 28378 before the concenred authority i.e.

          the District Transport Officer, Motihari (Respondent No. 2) and

          on such production, the authority shall take necessary steps for

          renewal of the registration of the said vehicle of the petitioner as

          expeditiously as possible preferably within a period of 4 weeks

          from the date of the receipt of the copy of this order.
           Patna High Court CWJC No.19453 of 2025(5) dt.10-03-2026
                                                      4/4




                                 6. With the above directions, the present writ petition

                     stands disposed of.



                                                         (A. Abhishek Reddy, J)
shakir/-

U


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