Patna High Court

Anticipatory bail is maintainable under the SC/ST Act where allegations are non-specific and lack prima facie substance.

Vishal Kumar Yadav @ Vishal Kumar vs The State of Bihar

Patna High CourtJUDGMENT: July 17, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

Five appellants filed an appeal under Section 14(A)(2) of the SC/ST (PoA) Act challenging the refusal of anticipatory bail by the Special Judge, Jamui

Source reference: p. 1-2

The prosecution alleged that the appellants abused the informant’s son with caste-based slurs and assaulted him, along with a cousin who intervened, causing a head injury

Source reference: p. 2

The defense argued that the allegations were non-specific, the injuries were superficial (a 1/5”x1/4”x1/4” laceration), and the case was politically motivated

Source reference: p. 2-3
02

Issues

1. Whether a prima facie case is established under the SC/ST (PoA) Act to justify the denial of anticipatory bail

Source reference: p. 3

2. Whether the nature of the allegations and medical evidence warrant the protection of the appellants under Section 482(2) of the BNSS

Source reference: p. 3
03

Law Applied

Section 14(A)(2) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989, regarding the maintainability of appeals against bail refusals

Source reference: p. 1

Sections 126(2), 115(2), 110, and 3(5) of the Bharatiya Nyaya Sanhita (BNS) and Sections 3(1)(r)(s) and 3(2)(va) of the SC/ST Act

Source reference: p. 2

Section 482(2) of the Bharatiya Nagarik Suraksha Sanhita (BNSS) regarding the conditions for granting bail

Source reference: p. 4
04

Reasoning

The court observed that the allegations against the five appellants were general and "omnibus," lacking specificity regarding who exactly hurled the abuse or caused the injuries

Source reference: p. 2

Upon reviewing the medical evidence, the court found the injury to be "superficial," contradicting the likelihood that five persons participated in a concerted assault

Source reference: p. 2

Heavily weight was given to the "political overtone" of the case and the lack of material to establish a prima facie case under the SC/ST Act

Source reference: p. 3

The court determined that the possibility of false accusation rendered the bar on anticipatory bail inapplicable in this instance

Source reference: p. 3
05

Holding

The High Court set aside the lower court's order dated 03.02.2026 and allowed the appeal

The court directed that in the event of arrest or surrender, the appellants be released on bail upon furnishing a bond of Rs. 10,000/- each with two sureties, subject to conditions including cooperation with the trial and a bailor being a close relative

Source reference: p. 3-4
Patna High Court

Original Court PDF

Vishal Kumar Yadav @ Vishal KumarvsThe State of Bihar

Patna High Court · July 17, 2026

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