Angani Oraon Vs the State of Jharkhand — Cheating and Forgery | Jharkhand HC (2025)

Angani Oraon Vs the State of Jharkhand — Cheating and Forgery | Jharkhand HC (2025)

What the court decided

AI extract

Outcome

Anticipatory bail application disposed of (not granted): petitioners to appear before the trial court and before the I.O. once every fifteen days during investigation; trial court to pass appropriate order in view of the Satender Kumar Antil judgment.

Issue for consideration

Whether the petitioners, apprehending arrest in Bero P.S. Case No.85/2023 (Sections 406, 420/34 IPC), are entitled to anticipatory bail under Sections 482 & 484 BNSS, 2023.

Court's answer

The punishment under Sections 406 and 420/34 IPC is seven years or less, and therefore the case falls to be dealt with under the Supreme Court judgment in Satender Kumar Antil.

Ratio / Principle

Since the petitioners have appeared before the I.O. and are cooperating, they have no real apprehension of being arrested; the anticipatory bail application at this stage is misconceived.

Key takeaways

The petitioners were directed to appear before the trial court and cooperate in the investigation by appearing before the I.O. once in every fifteen days, whereupon the trial court will pass an appropriate order in view of Satender Kumar Antil (supra).ratio¶19

Detailed headnote1 paragraphs

Anticipatory Bail — Bharatiya Nagarik Suraksha Sanhita, 2023, Ss. 482 & 484 — Offences under Sections 406, 420/34 IPC (punishment seven years or less) are covered by the Supreme Court guidelines in Satender Kumar Antil v. CBI — Where the applicants had already appeared before the Investigating Officer, were cooperating in the investigation, and the APP admitted there was no necessity to arrest them, the Court held the applicants had no real apprehension of arrest and the anticipatory bail application was misconceived at this stage — Applicants directed to appear before the trial court and before the I.O. once in every fifteen days; on such appearance, the trial court to pass an appropriate order in view of Satender Kumar Antil — Application disposed of accordingly (Ananda Sen, J.).

2025:JHHC:18550

IN THE HIGH COURT OF JHARKHAND AT RANCHI A.B.A. No.1631 of 2025

Angani Oraon, aged about 45 years, wife of Ramlakhan Oraon;

Ramlakhan Oraon, aged about 49 years, son of Gangu Oraon Both residents of Village- Uchri, P.O. + P.S.- Nagri, DistrictRanchi, Jharkhand, presently residing at village- Bero, P.O. & P.S. – Bero, District- Ranchi

… … Petitioners

Versus

The State of Jharkhand. … … Opposite Party

CORAM : SRI ANANDA SEN, J.

For the Petitioner(s) : Mr. Venkateshwar Gopal, Advocate For the State : Mr. Sunil Kumar Dubey, A.P.P. For the Informant : Mrs. Shruti Shrestha, Advocate

05/ 09.07.2025

Heard the parties.

2. This anticipatory bail application under Section 482 & 484 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, have been preferred by the petitioners apprehending their arrest in connection with Bero P.S. Case No.85/2023, for offence under Sections 406, 420/34 of the IPC. The case is presently pending before the Court of Judicial Magistrate, 1^st Class, Ranchi. 3. Learned counsel representing the petitioners submits

that the allegations in the F.I.R. is in respect of sale and purchase of land and playing fraud in the same transaction.

4. Learned A.P.P. representing the State opposes the prayer for anticipatory bail.

5. Admittedly, the punishment under the aforesaid two Sections are seven years or less and thus is covered by the judgment of Hon’ble Supreme Court in the case of Satender Kumar Antil Vs. Central Bureau of Investigation & Another , reported in ( 2022) 10 SCC 51 as well as the observation made in the case of Satender Kumar Antil Vs. Central Bureau of

2025:JHHC:18550

Investigation & Another reported in (2021) 10 SCC 773 .

6. The learned APP admits that the petitioners appeared before the I.O. and are cooperating in the investigation and there is no necessity to arrest the petitioners.

7. Considering the aforesaid submissions, I am of the view that these petitioners do not have any apprehension of being arrested, thus this anticipatory bail application, at this stage is misconceived. The petitioners should appear before the trial Court and will cooperate in the investigation by appearing before the I.O. once in every fifteen days. Once the petitioners appear, the trial Court will pass an appropriate order in view of the Judgment passed

by the Hon'ble Supreme Court in the case of Satender Kumar

Antil (supra) .

8. In view of the aforesaid observation, this Anticipatory Bail Application stands disposed of.

(ANANDA SEN, J.)

Sandeep. Cp-3