Ranjan Naik@Nayak Vs State of Odisha — Orissa HC (2026) — LawSathi Research

Ranjan Naik@Nayak Vs State of Odisha — Orissa HC (2026) — LawSathi Research

What the court decided

AI extract

Outcome

Criminal appeal allowed; impugned bail-refusal order set aside; appellant (CICL) to be released on bail on such terms and conditions as deemed fit and proper by the learned Court in seisin of the case.

Issue for consideration

Whether bail should be granted to the Child-in-Conflict with Law (represented by his legal guardian, paternal uncle) charged with offences punishable under Sections 363/366/376(2)(n)/313/323/294/506/342/34 IPC on the main allegation of rape, notwithstanding the Children's Court order dated 16.09.2025 refusing bail.

Court's answer

Bail to a CICL can be refused only if there exist reasonable grounds to believe that his release would bring him into association with any known criminal, or expose him to moral, physical or psychological danger, or defeat the ends of justice.

Ratio / Principle

No situation warranting refusal of bail (association with known criminals, exposure to moral/physical/psychological danger, or defeat of the ends of justice) prevails in this case; accordingly the Court proceeded on the nature and gravity of the alleged offences vis-a-vis the accusations against the CICL.

Key takeaways

In weighing the bail request the Court took into account the CICL's detention in the observation home since 19.01.2025 and the circumstances on record in their entirety, including the statement of the victim.ratio¶13
Given the CICL's inherent right to be presumed innocent until proven guilty at trial and the absence of any reported criminal antecedent of a similar nature, the Court, without expressing any opinion on merit, considered it proper to admit the appellant to bail.ratio¶13

Detailed headnote1 paragraphs

Juvenile Justice — Bail to Child-in-Conflict with Law (CICL) — Criminal appeal under Section 101 of the Juvenile Justice (Care & Protection of Children) Act, 2015 by Ranjan Naik @ Nayak, a CICL represented by his legal guardian (paternal uncle), charged with offences punishable under Sections 363/366/376(2)(n)/313/323/294/506/342/34 IPC on the main allegation of committing rape upon the victim, directed against the order dated 16.09.2025 of the learned Addl. Sessions Judge-cum-Special Judge, Children's Court, Nabarangpur (CT Case No. 3/2025(JV), arising out of JC Case No. 06 of 2025, corresponding to Tentulikhunti PS Case No. 10 of 2025) refusing bail. Held: bail to a CICL can be refused only where his release would bring him into association with any known criminal, expose him to moral, physical or psychological danger, or defeat the ends of justice; no such situation prevailed here. Taking into account the nature and gravity of the alleged offences vis-a-vis the accusations, the CICL's detention in the observation home since 19.01.2025, the statement of the victim, the CICL's inherent right to be presumed innocent until proven guilty at trial, and the absence of any criminal antecedent of a similar nature, the Court, without expressing any opinion on merit, admitted the appellant to bail, set aside the impugned order and allowed the appeal, leaving bail terms to the Court in seisin. (G. Satapathy, J., oral order dated 05.03.2026.)

IN THE HIGH COURT OF ORISSA AT CUTTACK CRLA No.170 of 2026

Ranjan Naik @ Nayak … Appellant

Mr. S.Mishra, Advocate

-versus-

State of Odisha … Respondent

Mr. P.Satapathy, Addl.PP

CORAM:JUSTICE G. SATAPATHY ORDER(ORAL):05.03.2026

Order No.

02.

This appeal under Section 101 of the Juvenile Justice (Care & Protection of Children) Act, 2015 (in short, “the Act”) by the appellant-petitioner is directed against the impugned order dated 16.09.2025 passed by the learned Addl. Sessions Judge-cum-special Judge, Children’s Court, Nabarangpur in CT Case No. 3/2025(JV) (Arising out of JC Case No. 06 of 2025) corresponding to Tentulikhunti PS Case No. 10 of 2025 refusing to grant bail to Child-in-Conflict with law (CICL) who is represented by his legal guardian (Paternal Uncle) in this criminal appeal for commission of offence punishable U/Ss. 363/366/376(2)(n)/313/ 323/294/506/342/34 IPC, on the main allegation of committing rape upon the victim.

Heard, Mr. Sabyasachi Mishra, learned counsel for the appellant-petitioner and Mr. P.Satapathy, learned Addl. PP in the matter and perused the record. 3. Bail to the CICL can only be refused if there exists reasonable materials for believing that the release of the child-in-conflict with law (CICL) would

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bring him into association with any known criminal or expose him to moral, physical or psychological danger or his release would defeats the ends of justice, but no such situation is prevailing in this case. In the aforesaid backdrop and taking into account the nature and gravity of the offences as alleged against the CICL visà-vis the accusation sought to be brought against him and regard being had to the detention of the CICL in observation home since 19.01.2025 and keeping in view the other circumstance on record in entirety including the statement of the victim and the inherent right of the CICL to be presumed innocent until proven guilty at the trial and no criminal antecedent of similar nature being reported against the appellant, this Court without expressing any opinion on merit, considers it proper to admit the appellant to bail.

Hence, the Criminal Appeal stands allowed and the impugned order is hereby set aside. Consequently, the appellant be released on bail on such terms and conditions as deems fit and proper by the learned Court in seisin of the case.

Accordingly, the CRLA stands disposed of.

(G. Satapathy)

Judge

Signature Not Verified

Digitally Signed Signed by: KISHORE KUMAR SAHOO kishore Reason: Authentication Location: Orissa High Court Date: 06-Mar-2026 14:44:14

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