Supreme Court sets aside judgement by Justice Prabhat Kumar Singh in a criminal case from Beerpur, Begusarai

In Manoj Sah vs. The State of Bihar (2026), Supreme Court's Division bench of Justices B.V. Nagarathna and R. Mahadevan passed a 7-page long order dated October 5, 2026, wherein, it granted leave and concluded: "Considering the circumstances on record, in our view, the appellant is entitled to the relief of anticipatory bail sought. We, therefore, allow this appeal and set aside the order passed by the High Court of Judicature at Patna dated 5.02.2026. We direct that in the event of arrest of the appellant, the Arresting Officer shall release the appellant on bail, subject to furnishing cash security in the sum of Rs.25,000/- (Rupees Twenty-Five Thousand only) with two like sureties."

This appeal had challenged the order dated February 5, 2026 passed by Justice Prabhat Kumar Singh of the Patna High Court. The appeal arose out of crime registered pursuant to FIR No.121 of 2023 dated July 23, 2023 lodged with PS Birpur District Begusarai, for the offences punishable under Sections 147, 341, 323, 379, 308, 504 and 506 of the Indian Penal Code. Section 147 deals with punishment for rioting, Section 341 deals with wrongful restraint. Section 323 deals with voluntarily causing hurt. Section 379 deals with punishment for theft. Section 308 deals with  attempt to commit culpable homicide. Section 504 deals with intentional insult to provoke breach of peace. Section 506 deals with criminal intimidation. While sections like 323, 341, and 504 are relatively minor and bailable, the inclusion of Section 308 makes it a major case. Anticipating arrest in connection with this crime, the appellants had preferred a criminal miscellaneous application before the High Court seeking anticipatory bail.

By order dated August 6, 2026, the Supreme Court had issued notice in the instant matter, while granting interim protection from arrest to the appellant. The appellant's counsel submitted before the Supreme Court that in the instant case the investigation has been concluded and charge sheet has also been filed as against the appellant herein. The appellant has cooperated with the investigation. In the circumstances, the impugned order may be made absolute as two other co-accused have also been granted the relief of anticipatory bail. Hence, this appeal may be allowed by setting aside the impugned

Earlier, in Manoj Sah vs. The State of Bihar (2026), Justice Prabhat Kumar Singh of Patna High Court had passed a 1-page long order dated February 5, 2026, wherein, he observed and concluded:""2. This is second anticipatory bail petition. Earlier, the petition, filed for grant of anticipatory bail on behalf of petitioner, stood rejected, vide order dated 25.09.2024 passed in Cr. Misc. No. 61306 of 2024. 3 . This application does not reveal any change of circumstances or new ground. 4. In view of the recent judgment of the Hon’ble Supreme Court in the case of G.R. Ananda Babu Vs. State of Tamil Nadu and Anrs reported in 2021 SCC OnLine SC 176, the second anticipatory bail on behalf of the petitioner is not maintainable. It is, accordingly, dismissed. 

Prior to this, in Manoj Sah & Ors. vs. The State of Bihar (2024), Justice Singh had passed a 3-page long order dated September 25, 2024, wherein, he drew on the submission of the APP of the State to that ".....there is specific accusation of assault against these petitioners and injuries allegedly caused by Petitioner No. 1 have been opined to be grievous in nature", he concluded:"6. Considering the aforesaid facts and circumstances and nature of injury sustained by informant the prayer for grant of anticipatory bail to Petitioner No. 1 is rejected. 7. Considering the fact that there is general and omnibus allegation of assault against petitioner Nos. 2 and 3 , in the event of arrest or surrender within six weeks from today, let the petitioner Nos. 2 and 3 , as named above, be enlarged on bail on furnishing bail bond of Rs.10,000/-(ten thousand) each with two sureties of the like amount each to the satisfaction of the learned Judicial Magistrate 1st Class Begusarai in connection with Birpur P.S. Case No. 121 of 2023 , subject to the conditions laid down under section 438(2) of the Code of Criminal Procedure. 8. With the aforesaid observations and directions, this application stands disposed of." The other two petitioners were: Pradeep Sah and Sonu Sah. 

The petitioners had approached the High Court for grant of anticipatory bail, apprehending their arrest in a case registered for the offence punishable under sections 147, 341 , 323 , 308 , 379, 504 and 506 of the Indian Penal Code. As per prosecution case, on the alleged date and time of occurrence, on the order of co-accused Sujit Kumar, these petitioners, along with other co-accused persons started assaulting the informant and his son Gautam Kumar with lathi-rod and khanti with the intention to kill them. It is next alleged that co-accused, Sujit, assaulted the informant's son with khanti on his head, causing injury to him. Petitioner No. 1 Manoj Sah, assaulted informant with lathi on his head, but the same hit on his hand, and he got a severe injury and fell on the ground. Thereafter, these petitioners assaulted informant with lathi, rod, and khanti. When the son of informant Gaurav Kumar and his wife came to save them, then these petitioners brutally assaulted them with lathi, rod, and khanti. It is further alleged that co-accused Jaymala Devi, snatched mangalsutra from the neck of the informant's wife . Petitioner no. 3 took out Rs. two thousand from the pocket of the informant. 4. It is submitted on behalf of these petitioners that both parties are agnates and dispute arose between them over partition of land for which a simple occurrence of maarpeet took place between them. Case and counter case . Allegation of assault is general and omnibus against these petitioners.

Supreme Court has reversed the order by Justice Singh.  

Supreme Court sets aside order by Justice Chandra Shekhar Jha, grants anticipatory bail due to compromise between informant, and appellant

In Shayam Mishra @ Shayam Kumar vs. The State of Bihar (2026), Supreme Court's Division Bench of Justices M.M. Sundresh and Prasanna B. Varale passed a 5-page order dated August 25, 2026, wherein, it set aside the 5-page long order dated June 25, 2026 by Justice Chandra Shekhar Jha of Patna High Court in a case from Badhurupiya, Sugauli, East Champaran. Supreme Court's order reads: "5) Inasmuch as this case involves a complaint at the behest of the informant and a counter complaint at the behest of the appellant, and the fact that the matter has been resolved between the parties, we are inclined to set aside the impugned order passed by the High Court and grant anticipatory bail to the appellant. 6) In such view of the matter, the impugned order dated 25.06.2026 passed by the High Court of Judicature at Patna in Criminal Miscellaneous No.40755 of 2026 is set aside and the appellant is granted anticipatory bail on such terms and conditions as may be imposed by the concerned Trial Court." 

The appellant is implicated as an accused in connection with F.I.R. No.480 of 2021 registered at P.S.: Sugauli, District: East Champaran, Bihar for the offences punishable under Sections 147, 149, 341, 323, 324, 307, 384, 379, 504 and 506 of the IPC. He was aggrieved by the rejection of the anticipatory bail applications by the Trial Court and the High Court. He approached the Supreme Court. The Court was informed that "the matter has been resolved between the appellant and the informant, via compromise."

Prior to this, in his order Justice Jha had recorded the submission by the A.P.P. for the State, while opposing the prayer of anticipatory bail of the petitioner, wherein, it was submitted that considering all available materials, the prayer of first anticipatory bail of the petitioner was rejected and, therefore, there is no occasion to reconsider this second prayer of anticipatory bail of the petitioner without having any changed circumstances, which would amount to review of earlier order passed by learned coordinate Bench of this Court, which is not permissible under law. It was also submitted by the A.P.P. that the offence, as alleged, is not compoundable in nature and, therefore, compromise is of no bearing. 

Justice Jha had concluded: "8. In view of aforesaid factual submission and by taking note of the fact as prima facie on the basis of subsequent compromise for non-compoundable offence, the earlier rejection order, which was passed by one of the learned coordinate Bench of this Court, cannot be reviewed by this Court, accordingly, on second consideration also, prayer of anticipatory bail of the  petitioner stands rejected."

The High Court's order recorded that it was the second prayer of anticipatory bail, after rejection of his first anticipatory bail by the 2-page long order dated February 9, 2023 of Justice Anjani Kumar Sharan in Cr. Misc. No. 2413 of 2023 dated February 9, 2023, wherein considering all available materials, as petitioner was specifically alleged to cause stab wound due to which the injured sustained grievous injury, his prayer of anticipatory bail was rejected. At the time of the rejection of the first anticipatory bail rejection, there was no compromise between the parties. 

The second anticipatory bail petition was preferred on the sole ground that now this matter was compromised between the parties. The counsel appearing on behalf of the petitioner had submitted before the High Court that the occurrence was free-fight in nature and petitioner’s side had also received injury during the occurrence. It was also submitted that now the petitioner was selected in Group ‘D’ service of Indian Railway, therefore, in view of compromise, sending the petitioner to jail would not serve any purpose of justice. 

In support of his submission, the counsel had relied upon para 22 of the decision in Naushey Ali vs. State of U.P. reported in 2025 SCC OnLine SC 292. Para-22 of the judgment reads:- “22. In Ramgopal v. State of M.P. (2022) 14 SCC 531, Surya Kant, J. speaking for this court, in a case involving a charge under Section 326 IPC, while annulling the proceedings, felicitously set out the statement of law and applied it to the facts of the said case as under:-“19. We thus sum up and hold that as opposed to Section 320 CrPC where the Court is squarely guided by the compromise between the parties in respect of offences “compoundable” within the statutory framework, the extraordinary power enjoined upon a High Court under Section 482 CrPC or vested in this Court under Article 142 of the Constitution, can be invoked beyond the metes and bounds of Section 320 CrPC. Nonetheless, we reiterate that such powers of wide amplitude ought to be exercised carefully in the context of quashing criminal proceedings, bearing in mind: 19.1. Nature and effect of the offence on the conscience of the society;
19.2. Seriousness of the injury, if any;
19.3 Voluntary nature of compromise between the accused and the victim; and
19.4 Conduct of the accused persons, prior to and after the occurrence of the purported offence and/or other relevant considerations.
20. Having appraised the aforestated parameters and weighing upon the peculiar facts and circumstances of the two appeals before us, we are inclined to invoke powers under Article 142 and quash the criminal proceedings and consequently set aside the conviction in both the appeals. We say so for the reasons that:
20.1. Firstly, the occurrence(s) involved in these appeals can be categorised as purely personal or having overtones of criminal proceedings of private nature. 
20.2. Secondly, the nature of injuries incurred, for which the appellants have been convicted, do not appear to exhibit their mental depravity or commission of an offence of such a serious nature that quashing of which would override public interest.
20.3. Thirdly, given the nature of the offence and injuries, it is immaterial that the trial against the appellants had been concluded or their appeal(s) against conviction stand dismissed.
20.4. Fourthly, the parties on their own volition, without any coercion or compulsion, willingly and voluntarily have buried their differences and wish to accord a quietus to their dispute(s).
20.5. Fifthly, the occurrence(s) in both the cases took place way back in the years 2000 and 1995, respectively. There is nothing on record to evince that either before or after the purported compromise, any untoward incident transpired between the parties.
20.6. Sixthly, since the appellants and the complainant(s) are residents of the same village(s) and/or work in close vicinity, the quashing of criminal proceedings will advance peace, harmony, and fellowship amongst the parties who have decided to forget and forgive any ill will and have no vengeance against
each other.
20.7. Seventhly, the cause of administration of criminal justice system would remain un-effected on acceptance of the amicable settlement between the parties and/or resultant acquittal of the appellants; more so looking at their present age.”

Supreme Court's order vindicates the position of petitioner's the counsel Prateek Tandon and the persuasive value of the decision in Naushey Ali vs. State of U.P. reported in 2025 SCC OnLine SC 292. It is apparent that Supreme Court has rejected the submission made by Nand Kishore Prasad, APP which is recorded in the order by Justice Jha. Unlike the High Court, the Supreme Court was not persuaded by APP's reasoning. 

Justice Chandra Shekhar Jha sets aside order by Chief Judicial Magistrate, Gopalganj in a theft and IT Act case from Gopalganj

In Sharvan Kumar Pandey vs. The State of Bihar & Anr. (2026), Justice Chandra Shekhar Jha delivereda 8-page long judgment dated July 20, 2026, wherein, he set aside order by Chief Judicial Magistrate, Gopalganj. justice Jha concluded: "10....it is clear that only on the basis of evidences as surfaced during any inquiry or trial of an offence, a summon can be issued to any person not being accused has committed any offence for which such person could be tried together with the accused. 11. In the present case, summon was not issued against petitioner on the basis of evidences surfaced during the trial. None of the prosecution witnesses have said anything incriminating during the trial against this petitioner, rather petitioner himself examined as PW-7. Interestingly, on the basis of petition of accused only, otherwise having all opportunity to examine himself on oath under section 315 of the Cr.P.C., this petitioner was summoned as an accused through impugned order, which is a perverse finding contrary to the settled position of law. 12. In view of aforesaid and by taking legal report of Hon’ble Apex Court in Neeraj Kumar’ case (supra), the impugned order dated 13.07.2018 as passed by learned Chief Judicial Magistrate, Gopalganj in connection with T.R. No. 1640/2018 arising out of Hathua P.S. Case No. 106 of 2015, is hereby quashed and set-aside qua petitioner. 13. Accordingly, this quashing petition stands allowed." The respondent no.2 was Surendra Nath Pandey. 

The judgement was passed upon hearing the petition filed for quashing the impugned order dated July 13, 2018 passed by learned Chief Judicial Magistrate, Gopalganj in connection with Tr. No. 1640/18 which arose out of Hathua P.S. Case No. 106 of 2015 registered for the offences punishable under Sections 420 & 379 of the I.P.C. and Section 66(C) of the Information Technology Act, whereby and whereunder on application of accused Rahul Kumar Jha, lC.J.M. issued summon against the petitioner to face the trial under Section 319 of the Code of Criminal Procedure.

The prosecution case was that as per FIR, informant alleged that Rs. 11,00,000/- was withdrawn in between April 30, 2015 to June 22, 2015 by the IRCTC from his Bank Account of State Bank of India, Hathua Branch. It was alleged that informant was a retired teacher and when he came to the Bank and verify his account, then, he came to know that fraud which was committed with his account. On the basis of written report, a First Information Report was lodged with Hathua Police Station. After lodging the FIR, police started investigation and submitted charge-sheet only against co-accused Rahul Kumar Jha for the offences punishable under Sections 420 & 379 of the I.P.C. and section 66(C) of the I.T. Act and investigation was kept pending to verify the I.P. address and on other points. Thereafter, trial court took cognizance only against accused Rahul Kumar Jha for the offences under sections 420 & 379 of the I.P.C. and Section 66(C) of the I.T. Act.

The petitioner 's counsel submitted that after taking cognizance the trial of the case begins with Tr. No. 1640/18 before the court of learned CJM, Gopalganj, where altogether seven (7) prosecution witnesses were examined and out of seven prosecution witnesses, this petitioner was also examined as PW-7 on 03.04.2018. It was pointed out that none of the prosecution witnesses, PW-1 to PW-6 named this petitioner qua his any involvement with the crime in question during the trial and the petitioner was examined as prosecution witness No.7, for the reason that he was the distributor of Cable Internet Connection through his company namely, M/s ANI Network Pvt. Ltd. to co-accused Rahul Kumar Jha, who alleged to misappropriate the amount of Rs. 11 Lakhs from the account of the informant for purchasing railway tickets and, thereafter, transferring the amount to his own account after cancellation of purchased railway tickets. It was submitted that co-accused Rahul Kumar Jha was not examined before the learned trial court in view of section 315 of the Cr.P.C., rather he made one application before the court of learned CJM, Gopalganj on 03.04.2018, stating therein that this petitioner may be summoned as an accused,which was allowed by the impugned order dated July 13, 2018. 

The counsel also relied upon ‘Para 7’ of the legal report of Supreme Court in Neeraj Kumar @ Neeraj Yadav vs. State of U.P. & Ors. reported in 2025 SCC OnLine SC 2639, which reads as under for better appreciation of the legal position in connection with issuance of summon under section 319 Cr.P.C. :-“7. It is no longer res integra that the power conferred under this Section is extraordinary and discretionary in nature, intended to be exercised sparingly and with due circumspection. While invoking it, the Court must be satisfied that the evidence appearing against the person sought to be summoned is such that it prima facie necessitates bringing such person to face trial. The degree of satisfaction required is higher than that warranted at the stage of framing of charge, yet short of the satisfaction necessary to record a conviction. Such satisfaction must rest on cogent and credible material brought on record during the trial, and not based on conjectures or speculations. In this regard, reference to a few judicial pronouncements of this Court would be apposite.
7.1. The Constitution Bench of this Court in Hardeep Singh v. State of Punjab [(2014) 3 SCC 92] extensively discussed the power conferred under Section 319 CrPC. Relevant part is
extracted hereunder: “90. … all that is required for the exercise of the power under Section 319 CrPC is that, it must appear to the court that some other person also who is not facing the trial, may also have been
involved in the offence. The prerequisite for the exercise of this power is similar to the prima facie view which the Magistrate must come to in order to take cognizance of the offence. Therefore, no straitjacket formula can and should be laid with respect to conditions precedent for arriving at such an opinion and, if the Magistrate/court is convinced even on the basis of evidence appearing in examination-in-chief, it can exercise the power under Section 319 CrPC and can proceed against such other person(s). It is essential to note that the section also uses the words “such person could be tried” instead of should be tried. Hence, what is required is not to have a mini-trial at this stage by having examination and cross-examination and thereafter rendering a decision on the overt act of such person sought to be added. In fact, it is this mini-trial that would affect the right of the person sought to be arraigned as an accused rather than not having any cross-examination at all, for in light of sub-section (4) of Section 319 CrPC, the person would be entitled to a fresh trial where he would have all the rights including the right to cross-examine prosecution witnesses and examine defence witnesses and advance his arguments upon the same. Therefore, even on the basis of examination-in-chief, the court or the Magistrate can proceed against a person as long as the court is satisfied that the evidence appearing against such person is such that it prima facie necessitates bringing such person to face trial. In fact, examination-in-chief untested by cross-examination, undoubtedly in itself, is an evidence.
xxx
106. Thus, we hold that though only a prima facie case is to be established from the evidence led before the court, not necessarily tested on the anvil of cross-examination, it requires much stronger evidence than mere probability of his complicity. The test that has to be applied is one which is more than prima facie case as exercised at the time of framing of charge, but short of satisfaction to an extent that the evidence, if goes unrebutted, would lead to conviction. In the absence of such satisfaction, the court should refrain from exercising power under Section 319 CrPC. …

xxx
110. In Lal Suraj [Lal Suraj v. State of Jharkhand, (2009) 2 SCC 696 : (2009) 1 SCC (Cri) 844], a two-Judge Bench held that there is no dispute with the legal proposition that even if a person had not been chargesheeted, he may come within the purview of the description of such a person as contained in Section 319 CrPC. A similar view had been taken in Lok Ram [Lok Ram v. Nihal Singh, (2006) 10 SCC 192 : (2006) 3 SCC (Cri) 532 : AIR 2006 SC 1892], wherein it was held that a person, though had initially been named in the FIR as an accused, but not charge-sheeted, can also be added to face the trial. …. …… ……”

Justice Purnendu Singh sets aside judgment of 2013 by Adhoc Additional Sessions Judge, Ara in a case of kidnapping for marriage

In Harendra Yadav vs. The State Of Bihar (2026), Justice Purnendu Singh delivered a 16-page long judgement dated June 30, 2026, wherein, he concluded:"24. The impugned judgment dated 18.04.2013 and order of sentence dated 20.04.2013 passed in Sessions Trial No. 149 of 2005 arising out of Ara Nawada P.S. Case No. 85 of 2003 by the learned Adhoc Additional Sessions Judge II, Ara is hereby quashed and set aside. Consequently, the above-named appellant is acquitted from all the charges levelled against him. Since the appellant is on bail, as such, he is discharged from the liability of his bail bond. The fine deposited by the appellant, if any, shall be refunded to him. 25. Accordingly, the present appeal is allowed. 26. There shall be no order as to cost. 27. Office is directed to send back the lower court records along with a copy of the judgment to the learned District Court forthwith."

The judgement was delivered upon hearing the criminal appeal which was preferred against the judgment of conviction dated April 18, 2013 and order of sentence dated April 20, 2013 passed in a Sessions Trial of 2005. The case arose out of a Ara Nawada P.S.Case of 2003, by the Adhoc Additional Sessions Judge IInd, Ara, whereby the trial court had convicted the appellant for the offence committed under Section 366 and 120 of the Indian Penal Code and sentenced him to undergo ten years Rigorous Imprisonment (R.I.) and to pay a fine of Rs.10,000.

The prosecution case was that the informant, Yogendra Yadav, while working in a Cotton Mill at Sapar, Rajkot (Gujarat), became acquainted with accused Nagendra Yadav, who was employed in the same establishment. On February 17, 2003, when the informant, along with his wife and minor son, was returning to his native village, Nagendra Yadav accompanied them and allegedly persuaded them to visit his residence at Ara Town. It was alleged that after reaching Ara on February 19, 2003 and staying at the khatal of Nagendra Yadav, the informant found the very next morning that his wife, son and a box containing Rs.90,000/- were missing. Upon inquiry from the co-accused Ram Ayodhaya, he was informed that his wife and son had gone to the River Ganga and would return later, however, allegedly co-accused Ram Ayodhaya had allegedly served him food containing intoxicant and after consuming the same he remained unconscious for several days. The day he regained consciousness he found that his wife, son and the cash box were missing. Subsequently, on February 26,.2003, when the informant, along with witnesses had again approached the accused persons to know about the whereabouts of his son and wife, allegedly the accused demanded Rs.1,00,000/- to release his wife and son and in case of failure of fulfillment of the 
demand he had threatened that they would be killed, which led to institution of the complaint before the Chief Judicial  Magistrate.

The Magistrate directed the local police for investigation in exercise of power under Section 156 (3) of Cr.P.C., pursuant to which Ara Nawada P.S. Case No. 85 of 2003 was registered for the commission of offences under Sections 364, 379, 328 and 120(B) of the Indian Penal Code (I.P.C.) against four accused persons, including the appellant. 

The police submitted a charge-sheet against the appellant under Sections 366, 364, 379 and 120(B) of the Indian Penal Code on November 26, 2023. Cognizance was taken on February 7, 2004, and the case was committed to the Court of Sessions on March 18, 2005. Charges were framed against the appellant on January 7, 2006 leading the conviction of the appellant upon completion of trial. 

The counsel of the appellant submitted that the prosecution failed to establish the charges beyond reasonable doubt. He contended that the main allegation is against co-accused Nagendra Yadav and the appellant were implicated solely because he is the brother of the co-accused, in spite of the fact, no material came against the appellant that he had participated in the alleged abduction of the informant’s wife or son and he had shared any common intention with the main accused, so as, to attract the provisions
of 120-B of the IPC. 

He referred to the testimony of Om Prakash Yadav, the P.W.1, the son of the informant. He in his examination-in-chief, gave varying versions regarding the circumstances in which his mother allegedly went away on her own, which creates serious doubt about the veracity of his testimony and the prosecution case as a whole. 

The counsel submitted that neither any witness nor any material was brought on record in course of trial to suggest that the victim was kidnapped by the appellant as would also appear from the deposition of the victim Meera Devi, the P.W.5, who is the victim and she also has not supported the prosecution story. 

P.W.5 in her statement in police custody that she on her own had accompanied the co-accused which demolishes the accusation of kidnapping and, as such, the prosecution having miserably failed to prove the charges against the appellant beyond reasonable doubt, renders the impugned judgment of conviction and order of sentence to be set aside.

APP appeared for the State. While opposing the appeal, he submitted that the District Court, after considering all the evidences on record and exhibits submitted on behalf of the parties during the course of trial, has erred no mistake in passing the order conviction against the appellant.

The conviction of the appellant is under Section 366 and Section 120-B of Indian Penal Code. Section 366 reads: “Kidnapping, abducting or inducing woman to compel her marriage, etc.—Whoever kidnaps or abducts any woman with intent that she may be compelled, or knowing it to be likely that she will be compelled, to marry any person against her will, or in order that she may be forced or seduced to illicit intercourse, or knowing it to be likely that she will be forced or seduced to illicit intercourse, shall be punished with imprisonment of either description for a term which may extend to ten years, and shall also be liable to fine; and whoever, by means of criminal intimidation as defined in this Code or of abuse of authority or any other method of compulsion, induces any woman to go from any place with intent that she may be, or knowing that it is likely that she will be, forced or seduced to illicit intercourse with another person shall be punishable as aforesaid.

Section 120B reads: "Punishment of criminal conspiracy.—(1)Whoever is a party to a criminal conspiracy to commit an offence punishable with death, imprisonment for life or rigorous imprisonment for a term of two years or upwards, shall, where no express provision is made in this Code for the punishment of such a conspiracy, be punished in the same manner as if he had abetted such offence.  (2)Whoever is a party to a criminal conspiracy other than a criminal conspiracy to commit an offence punishable as aforesaid shall be punished with imprisonment of either description for a term not exceeding six months, or with fine or with both."

Justice Singh observed: "12. To constitute the offence of abduction, it must be shown that a person was unlawfully taken away or induced to move from one place to another either by the use of force or through deceitful means. The essence of the offence lies in the intention with which the accused acts. It is the accused's conduct, volition and underlying purpose that are determinative of whether the offence is made out. The crucial issue in every case is the intention accompanying the act of taking or inducing the woman to leave a particular place. Once the requisite criminal intent on the part of the accused is established, the offence stands complete irrespective of whether the intended object was ultimately achieved and regardless of whether the woman subsequently consented to marriage or sexual relations. 13. It is a well-settled principle that, for bringing home a charge under Section 366 IPC, the prosecution must establish not merely that the woman was taken or induced to move from one place to another, but also that such inducement was effected by force or deceitful means and was accompanied by the requisite criminal intent contemplated under the provision. The prosecution is further required to prove that the abduction was committed with the intention that the woman may be compelled to marry any person against her will, or that she may be forced or seduced to illicit intercourse, or with the knowledge that such consequences were likely to follow. Mere proof of abduction, by itself, is insufficient to attract the provisions of Section 366 IPC. The gravamen of the offence lies not only in the act of taking away the woman but also in the specific purpose and intention behind such act. Therefore, unless the prosecution succeeds in proving that the abduction was for one of the purposes enumerated under Section 366 IPC, a conviction under the said provision cannot be legally sustained.

Justice Singh drew on Supreme Court's decision in Kavita Chandrakant Lakhani vs. State of Maharashtra, reported in (2018) 6 SCC 664, wherein, it observed that to constitute the offence of “abduction”, a person must be carried off illegally by force or deception, that is, to compel a person by force or deceitful means to induce to go from one place to another. The intention of the accused is the basis and the gravamen of an offence under this section. The volition, the intention and the conduct of the accused determine the offence; they can only bear upon the intent with which the accused kidnapped or abducted the woman, and the intent of the accused is the vital question for determination in each case which is reproduced hereinafter:“16. In order to constitute the offence of “abduction”, a person must be carried off illegally by force or deception, that is, to compel a person by force or deceitful means to induce to go from one place to another. The intention of the accused is the basis and the gravamen of an offence under this section. The volition, the intention and the conduct of the accused determine the offence; they can only bear upon the intent with which the accused kidnapped or abducted the woman, and the intent of the accused is the vital question for determination in each case. Once the necessary intent of the accused is established, the offence is complete, whether or not the accused succeeded in effecting his purpose, and whether or not the woman consented to the marriage or the illicit intercourse.

The judgement reads: ".....to constitute an  offence under Section 366 IPC, it is necessary for the prosecution to prove that the accused induced the complainant woman or compelled by force to go from any place, that such inducement was by deceitful means, that such abduction took place with the intent that the complainant may be seduced to illicit intercourse and/or that the accused knew it to be likely that the complainant may be seduced to illicit intercourse as a result of her abduction. Mere abduction does not bring an accused under the ambit of this penal section. So far as charge under Section 366 IPC is concerned, mere finding that a woman was abducted is not enough, it must further be proved that the accused abducted the woman with the intent that she may be compelled, or knowing it to be likely that she will be compelled to marry any person or in order that she may be forced or seduced to illicit intercourse or knowing it to be likely that she will be forced or seduced to illicit intercourse. Unless the prosecution proves that the abduction is for the purposes mentioned in Section 366 IPC, the court cannot hold the accused guilty and punish him under Section 366 IPC.” This proposition of law was reiterated by the Supreme Court in Mohd. Yousuff vs. State of Karnataka, reported in (2021) 16 SCC 461. 

Justice Singh explored as to whether the judgment of conviction dated April 18, 2013 and order of sentence dated April 20, 2013 passed against the appellant for the offences under Sections 366 and 120-B of the IPC was justified. During the trial, the prosecution has examined altogether four witnesses. P.W.1 – Om Prakash Yadav: P.W.1 is the son of the informant and one of the alleged victims. In his deposition, he stated that while returning from Sapar (Rajkot) along with his parents, accused Nagendra Yadav accompanied them and persuaded them to visit Ara. According to him, after staying at the khatal of Nagendra Yadav, he and his mother were taken away by accused Nagendra Yadav and were kept at different places, including Kudhwa Tola and Mumbai. He also stated that when they later came to Buxar Railway Station, he met his father, whereupon the accused persons fled away with his mother. In cross-examination, he admitted that he was a student of Class V at the relevant time and supported the fact that he had stayed with his mother at Kudhwa Mohalla and Mumbai. The trial court found his testimony corroborative of the evidence of P.W.2, Yogendra Yadav, the Informant. 

P.W.2 identified his signature on the complaint petition. He substantially reiterated the allegations made in the complaint petition. He deposed that while returning from Sapar (Rajkot) on February 17, 2003 along with his wife and son, accused Nagendra Yadav persuaded them to visit Ara Town. After reaching the khatal of the accused persons and taking meals, he went to sleep and on waking found his wife and son missing. He stated that accused Ram Ayodhaya informed him that they had gone to the Ganga for bathing and worship. He further alleged that after consuming food provided by the accused persons, he became unconscious for several days and, upon regaining consciousness, found that his wife and son were still missing. He also deposed that the accused persons later demanded Rs.1,00,000/- for their release. In cross-
examination, he stated that Meera Devi was his second wife and that he had married her in the year 1995 after separating from his first wife. The trial court found that his evidence regarding the stay at the khatal and subsequent disappearance of his wife and son remained substantially unshaken.

P.W.3–SurendraYadav, did not support the prosecution case and was declared hostile. He denied having any knowledge regarding the alleged occurrence and stated that he had not been interrogated by the police in connection with the case. Nothing material supporting the prosecution case could be elicited from his evidence.

P.W.4–Vindhyachal Yadav was also declared hostile by the prosecution. He denied any knowledge of the
alleged occurrence and did not support the prosecution version. His evidence did not advance the prosecution case in any manner.

P.W.5 – Meera Devi, the alleged victim and the second wife of the informant according to the prosecution case did not support the prosecution version and was declared hostile. She stated that she had never married the informant and also alleged that her statement recorded before the Magistrate had been made under pressure from the police. She specifically denied the prosecution allegation that accused Nagendra Yadav had forcibly abducted her after administering poison to the informant. Her evidence was completely contrary to the prosecution case and substantially weakened the allegation of kidnapping.

P.W.6 – Daya Ram Singh @ Dayanand Yadav was declared hostile by the prosecution. He denied any knowledge of the alleged occurrence and stated that he had not been questioned by the police regarding the incident. No material supporting the prosecution case emerged from his testimony.

P.W.7 – Singhasan Yadav was also declared hostile. He denied knowledge of the occurrence and did not support the prosecution case. His evidence was of no assistance to the prosecution.

P.W.8 – Paras Nath Yadav, (referred to as P.W.9 in portions of the trial court judgment) was declared hostile by the prosecution. He denied having any knowledge of the alleged incident and did not support the prosecution version. Nothing favourable to the prosecution could be elicited from his evidence.

Justice Singh recorded that on the basis of materials surfaced during the trial, the appellants/accused were examined under Section 313 of the Cr.PC by putting incriminating circumstances/evidences surfaced against them, which they denied and show their complete innocence. 

Justice Singh observed:"....I find that the learned trial Court has erred in concluding that the present appellant, Harendra Yadav, shared the common intention or was a party to any conspiracy with the co-accused, Nagendra Yadav, so as, to attract the allegations under Sections 366 and 120B IPC. 22. From the evidence available on record, it transpires that the main allegation of taking away the victim is directed against co-accused Nagendra Yadav. Significantly, the alleged victim, P.W.5 (Meera Devi), has herself not supported the prosecution case and has categorically denied that she was forcibly abducted by the accused persons. She has further denied material aspects of the prosecution story and has not attributed any overt act whatsoever to the present appellant. Mere relationship of being brother of the co-accused and his presence at the place of occurrence cannot be established that there was prior meeting of mind for establishing offence under Section 366 and 120(B) of I.P.C without any independent corroboration."

The judgement reads: "23. The record further reveals that P.Ws.3, 4, 6, 7 and 8 were declared hostile and did not support the prosecution case, leaving the prosecution to rest substantially upon the testimonies of P.Ws.1 and 2. Even their evidence does not disclose any specific act on the part of the appellant indicating that he had induced, compelled, or deceived the victim into going from one place to another, nor is there any material to establish that he possessed the requisite intention contemplated under Section 366 IPC. Likewise, there is no cogent evidence demonstrating any agreement or meeting of minds between the appellant and the co-accused so as to constitute the offence of criminal conspiracy under Section 120B IPC. From the records of the case and the testimony of the victim herself, it is evident that no specific allegation has been levelled against the appellant so as to attract the ingredients of the aforesaid offences. In such circumstances, the finding of guilt recorded by the trial Court is not borne out of the evidence on record."

Supreme Court upholds 2017 judgement by Justices Rakesh Kumar, Mohit Kumar Shah affirming judgement by Trial Court in a 43 year old case from Jamalpur Kodai, Gaighat, Muzaffarpur

In Mahendra Rai alias Harendra Narain Singh & Ors vs. The State of Bihar (2026), Supreme Court's Division Bench of Justices Sanjay Karol and N Kotiswar Singh delivered a 13-page long judgement dated May 26, 2026, wherein, it concluded:"28. We are satisfied that the prosecution has proved beyond reasonable doubt the ingredients of the offences charged against the appellants. The concurrent findings recorded by the Trial Court and affirmed by the High Court are based upon proper appreciation of evidence and do not suffer from any perversity warranting interference under Article 136 of the Constitution of India. 29. The brutality of the incident, in which five persons belonging to the same family lost their lives and several others including women and children sustained serious injuries, shocks the judicial conscience. The Courts below have rightly observed that the case leaves no room for misplaced sympathy or leniency. 30. In view of the foregoing discussion, we find no ground to interfere with the impugned judgment and order passed by the High Court. 31. Consequently, the appeals stand dismissed. 32. The surviving accused persons, except those who have been granted the benefit of juvenility by this Court or Courts below, are directed to surrender forthwith before the Trial Court concerned and serve the remaining part of their sentence. Their bail bonds, if any, stand cancelled." 

The High Court's 142-page long judgement dated August 3, 2017 was delivered by Patna High Court's Division Bench of Justices Rakesh Kumar and Mohit Kumar Shah. It was authored by Justice Kumar. 

The High Court's order dated recorded hat Vidya Nand Rai son of Bhujawan Rai,  Ramadhar Rai, son of Subudh Lal Rai and Rama Nand Rai, son of Mahendra Rai were juvenile on the date of occurrence. Justice Kumar's judgement remitted their cases to the Juvenile Justice Board for imposing appropriate fine to be paid to the family of the victim. The trial court's sentence in respect of these three appellants was set aside. Their current fate is not known. 

Referring to the judgement authored by Justice Kumar, Supreme Court observed: “The High Court has meticulously summarised the role of each accused person and identified those who ignited the straw, those who set the house on fire, those who chased the fleeing victims and those who inflicted fatal blows upon the deceased persons”. All the appellants were residents of village Jamalpur Kodai, Police Station Gaighat, District Muzaffarpur and they were convicted by 3rd Additional Sessions Judge, Muzaffarpur on June 5, 1989 in Sessions Trial No. 21 of 1985 and 127 of 1985. 

Supreme Court asserted: "20. Having carefully considered the submissions advanced and upon perusal of the entire material on record, we find no merit in the appeals. 21. The High Court’s assessment of the evidence is detailed and reasoned.....23. The findings recorded by the High Court clearly establish that the accused persons constituted an unlawful assembly, were armed with deadly weapons and acted in furtherance of their common object of setting the house ablaze and causing death of members of the family of Chandra Shekhar Choudhary. 24. Once the common object of the unlawful assembly stands established, every member thereof becomes vicariously liable for acts committed in prosecution of such common object. The liability contemplated under Section 149 IPC squarely stands attracted in the facts of the present case." 

 With regard to Jagannath Ravidas, "both the Trial Court and the High Court have concurrently found that he had actively facilitated the commission of the offence by disarming the victims at a crucial stage and thereby emboldening the mob. We find no reason to take a different view."

The court dismissed the appeals filed by Mahendra Rai alias Harendra Narain Singh and others, the convicts had challenged the judgment of the High Court, which had upheld their conviction and life imprisonment awarded by the trial court. The incident occurred on the day of Holi in March 1983 in a village in Muzaffarpur district. A mob of at least 58 persons, armed with deadly weapons, surrounded the house of Chandra Shekhar Choudhary, set it on fire and brutally killed five persons while injuring several others, including women and children. The court noted that the evidence clearly established that the accused formed an unlawful assembly, were armed with lethal weapons, and acted in furtherance of their common object to set the house ablaze and cause the deaths. Once the common object is proved, every member becomes vicariously liable for the acts committed. The accused actively participated at different stages — surrounding the house, setting it on fire, chasing the victims, and assaulting them. Several appellants had died during the pendency of the appeals before the High Court, leading to abatement of their cases. It directed the surviving convicts — except those who received the benefit of juvenility — to surrender immediately before the trial court and serve the remaining part of their sentences.

The High Court had affirmed the conviction and sentence awarded by the Trial Court against the appellants in connection with a gruesome incident of mass violence which took place on March 29, 1983 in village Jamalpur Kodai, Gaighat, Muzaffarpur. 

The incident was reported to the police, leading to registration of Gaighat P.S. Case of 1983. Upon completion of investigation, charge-sheets were laid and the accused persons were sent up for trial. Charges were framed against the accused persons under Sections 147, 148, 436, 302/149, 324/34, 323 and 379 of the Indian Penal Code, 1860. The accused Jagannath Ravidas, the then Circle Officer, was separately charged under Sections 302/109, 436/109, 379/109, 324/109 and 323/109 IPC on the allegation that he had actively abetted the commission of the offences.

The prosecution case disclosed that the genesis of the occurrence lay in an earlier dispute relating to a pumping set and refusal by the prosecution side to withdraw a criminal case concerning the alleged loot of a khesari crop. On the date of occurrence, which coincided with the festival of Holi, a large mob armed with deadly weapons including lathi, bhala, garasa and farsa surrounded the house of Chandra Shekhar Choudhary. At the relevant time Mahanth Indradeo Jyoti, one of the deceased, was attempting to defend the inmates of the house with his licensed gun and revolver. The prosecution had alleged that Jagannath Ravidas, the then Circle Officer, arrived at the place of occurrence, forcibly seized the licensed firearm and revolver from the deceased, displayed the same before the mob and thereby emboldened the assailants to proceed with the attack. Immediately thereafter, the mob allegedly set the house ablaze. The family members who attempted to flee from the burning house towards the southern field were chased and mercilessly assaulted by the members of the unlawful assembly.  The investigation disclosed that Mahanth Indradeo Jyoti, Braj Bhushan Choudhary, Dr. Indranand Mishra, Lalan @ Ravi Bhushan Choudhary, and Anil Kumar Jha, died as a result of ante-mortem injuries sustained during the occurrence. The injured persons included Chandra Shekhar Choudhary, Mani Kumari, Uma Devi, Maheshwari Devi, Satyendra Jha, Saraswati Devi, Urmila Devi, Murti Devi, Ram Chandra Mahto, Abinash Choudhary, Dauli (child), Arvind Kumar, Usha Mishra, Rita Devi, Punam Kumari, Doyal Mona, Ajay Kumar Choudhary, Munish Kumar and others, many of whom had sustained grievous injuries. In support of its case, the prosecution examined 46 witnesses including numerous injured eyewitnesses. The defence examined 13 witnesses. 

Advocate Dr. Gopal Krishna who is an amicus curiae in the special laws/courts matter observed:" The Court heavily relied on Section 149 of the Indian Penal Code (IPC). It reiterated that once a common object of an unlawful assembly is established, every member of that assembly is vicariously liable for the actions committed in prosecution of that object. The defense argued that several appellants were mere spectators during the incident. It rejected this argument, noting that the mob was heavily armed with lethal weapons (lathis, bhalas, farsas) and acted cohesively to set a house on fire and execute the victims. It gave conclusive weight to the testimonies of the injured eyewitnesses, stating that their statements, backed by corroborating medical evidence, completely proved the prosecution's case beyond a reasonable doubt.The Court noted that the extreme brutality of the 1983 incident "shocks the judicial conscience" and leaves zero room for leniency or misplaced sympathy. While the Court maintained the benefit of juvenility previously extended to a few individuals, it dismissed the appeals for the remaining surviving convicts and directed them to surrender immediately to serve out the rest of their sentences."

 

Supreme Court sets aside order by Justice Sandeep Kumar in a UAPA case

In Ram Pravesh Yadav vs. The State of Bihar (2026), Supreme Court's Division Bench of Justices M.M. Sundresh  and N. K. Singh passed a 5-page long order, wherein, it set aside the order by Justice Sandeep Kumar of Patna High Court. The order reads:"....we are inclined to grant bail to the appellant. Accordingly, the impugned order is set aside and the appellant is granted bail on terms and conditions to the satisfaction of the concerned Trial Court." 

The counsel appearing for the appellant submitted that the facts have been wrongly recorded by the High Court to the effect that the appellant was absconding. The appellant was, in fact, under incarceration from 2016 to 2024, in connection with a different FIR. Although it was stated that there were a number of cases in which the appellant was involved, he was acquitted in most of the cases. In any case, taking into consideration the period of incarceration undergone, he was entitled to bail, particularly, when the co-accused have been granted bail.

The appellant sought regular bail in connection with FIR No.88/2011, dated 17.06.2011, registered at Police Station Amas, District Gaya, Division-Sherghati, Bihar for the offences punishable under Sections 147, 148, 149, 341, 323, 307, 379, 384, 386, 435, 427, 120(B) of the Indian Penal Code, 1860, Section 27 of the Arms Act, Section 17 of the Criminal Law Amendment Act and Section 13 of the Unlawful Activities (Prevention) Act, 1967. 

In the Supreme Court, the counsel appearing for the State admitted that it was not in dispute that the appellant was indeed under incarceration from 2016 to 2024. The finding recorded by the High Court is not correct. Additionally, the appellant has been under incarceration for a further period of more than 1 year. The co-accused was granted bail. 

In his order Justice Kumar had recorded: 3. As per the prosecution case, the petitioner and others are said to have stopped the trucks near the Sao Kala Toll Plaza and have set ablaze the trucks. 5. It has been submitted by the learned counsel for the petitioner that the petitioner has been acquitted in 40 cases registered against him and he has been granted bail in seven more similar cases. 6. Learned APP for the State Shri Jharkhandi Upadhyay submits that from the records, it appears that the petitioner is an absconder in a case of year 2011 and he is an active naxal." The High Court's order reads:"Considering the aforesaid submission of the learned APP for the State, this Court is not inclined to grant bail to the petitioner. 8. Accordingly, this application is dismissed." Now the Supreme Court has reversed this order.  

"this matter should not have reached Supreme Court, Patna High Court should have exercised its jurisdiction:Justice J. B. Pardiwala

In Vishwajeet Kumar @ Vishwajeet Saini vs. State of Bihar & Anr.(2026), Supreme Court's Division Bench of Justices J. B. Pardiwala and K.V. Vishwanathan passed an order dated January 20, 2026. The Petition for Special Leave to Appeal (Criminal) arose out of impugned final order dated November 24, 2025 by Justice Prabhat Kumar Singh of Patna High Court. Notably, the Trial as on date is pending in the Court of Exclusive Special Judge (SC/AT Act), Civil Court (Sadar), Patna.

The High Court of Patna had declined anticipatory bail to the petitioner in connection with ABP No. 79 of 2025 arising out of SC/ST P.S. Case No. 03 of 2018, registered under Sections 147, 148, 149, 448, 341, 323, 324, 307, 379, 354(B), 504, 506 of the Indian Penal Code respectively and Sections 3(l)(r)(g)(p)(w)(z) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, respectively. 

Supreme Court observed:"4. It appears from the materials on record that after the registration of FIR, investigation was undertaken and at the end of the investigation, the Investigating Agency thought fit to file a Closure Report in so far as the involvement of the present petitioner in the alleged crime is concerned. 5. Pursuant to the filing of the Closure Report, notice was issued by the Court concerned to the defecto-complainant. After hearing the defacto-complainant and the State, the Closure Report was ultimately accepted. The order passed by the Court concerned accepting the closure report attains finality. 6. In such circumstances, referred to above, the petitioner was not put to trial. Charge-sheet came to be filed against other co- accused.7. It appears that the original defecto-complainant i.e. the victim entered the witness box for her oral testimony and in the course of her oral testimony, she reiterated the very same allegations levelled by her against the petitioner in the FIR. Thereafter, she preferred an application under Section 319 of the Code of Criminal Procedure, 1973 to add the present petitioner as an accused in the trial.

The petitioner being dissatisfied with the order passed by the Trial Court, adding him as an accused in exercise of powers under Section 319 of the Code, challenged the order before the High Court. However, the petitioner apprehending arrest at the hands of the Police prayed for anticipatory bail which came to be declined. This prosecution is of the 2018. This matter should not have travelled to the Supreme Court. It was expected of the High Court to exercise its discretion in accordance with law, having regard to the peculiar facts and circumstances of this case.

Supreme Court concluded:"We need not say anything further as the original order passed by the Trial Court adding the petitioner as an accused has been challenged before the High Court and the High Court is in-seisin of the original order.12. In such circumstances, referred to above, we order that in the event of arrest of the petitioner by the Police in connection with the offence referred to above, he shall be released on bail, subject to terms and conditions that the Investigating Officer may deem fit to impose.13. Once the petitioner is released by the IO, he shall thereafter appear before the Trial Court and furnish fresh bail.14. Whether the petitioner should face the trial or not will be subject to the final outcome of the petition pending in the High Court.15. With the aforesaid, the Special Leave Petition stands disposed of."

Drawing on decision of the Supreme Court, passed in Bachu Das vs. State of Bihar & others, Justice Singh had concluded:"4. Considering the law laid down by the Hon’ble Supreme court in case of Bachu Das (supra), instant appeal filed for pre-arrest bail to the appellant, is dismissed as being not maintainable."

Battling a "fake and fabricated case", suicidal Dr Shweta Burnwal reaches Patna High Court, writes to Prime Minister

Dr. Shweta Burnwal filed a criminal miscellaneous petition No. 11352/2024 on January 20, 2024 in the Patna High Court on the subject of quashing of the order of cognizance arising out of complaint of Khagaria Police Station Case No.: 128 dated April 1, 2023. It was registered in the High Court on February 9, 2024. Bipin Kumar is the additional respondent who has got an vakalatnama filed on April 15, 2024 by his counsel. 

It is apparent that the matter is pending  before the Court of Justice Partha Sarthy because some defects have not yet been cured as yet. 

In the meanwhile, in a letter dated May 29, 2024 addressed to the Prime Minister, Dr. Shweta Burnwal has informed that Bipin Kumar, her husband is trying to kill her. She was filed a case against him under Section 498 A of Indian Penal Code on September 12, 2021. She was married to him on February 20, 2020. Because of harassment by her husband, she started living with her parents in Kolkata since March 14, 2021. Her mother is suffering from cancer. She wrote, "my husband has been harassing me and my family in all its forms, both mentally and physically. My husband, Bipin Kumar, is close to the judiciary and has filed false cases against me and my maternal grandparents in just eight months." The notice of the cases against her and her family has not been received by her and her family (father, brother, sister, brother-in-law, two maternal uncles and Mami). She has claimed that all the advocates of the Khagaria Court have refused to take up her case under the influence of her husband. 

In her letter to the Prime Minister, she wrote, "मेरे पति बिपिन कुमार न्यायपालिका में नजदीकि के कारण और अपनी बदनियति से झूठे मुकदमे कर महज आठ (8) महीने में ही crpc 82 और 83 (कुर्की, जपती) मुझे और मेरे ननिहाल के परिवारों पर लगवा दिए हैं ।इस केस (128c/ 2023) की सूचना मुझे और मेरे परिवार वालों(पिता,भाई,बहन, बहनोई,दो मामा, मामी और मैं) को सीआरपीसी 82 लगने तक तक किसी भी माध्यम से प्राप्त नहीं हुई जैसा कि कोर्ट के आर्डर शीट में भी लिखा गया है कि तामिला अप्राप्त (जिसकी कॉपी इसके साथ संलग्न कर रही हुं)." She concluded her letter saying, "यह बहुत खेद के साथ कहना पड़ रहा है कि मैं मानसिक रूप से डिप्रेशन में जा रही हूं और साथ ही मैं इस विकट परिस्थिति में आत्महत्या करने की और अग्रसर हो रही हूं।" 

The other side of the story can be gathered from the FIR and the complaint letter available at https://in.docs.wps.com/l/sIDnP4tiCAqmUhbMG?v=v2 which was filed by Vinay Kumar, the brother of Bipin Kumar, a Court Manager in Khagaria Court. In the compliant it has been alleged that Bipin Kumar's wife and her family members have indulged in criminal  intimidation and criminal activities on the body and the property of the family of the complainant including his mother.