Pramila Devi @ Parmila Devi Vs The State of Bihar through the Director General of Police, Sardar Patel Bhawan, Bailey Road, Patna — Patna HC (2026) — LawSathi Research

Pramila Devi @ Parmila Devi Vs The State of Bihar through the Director General of Police, Sardar Patel Bhawan, Bailey Road, Patna — Patna HC (2026) — LawSathi Research

What the court decided

AI extract

Outcome

Writ application disposed of with a direction to the investigating agency to conclude the investigation of the case, nab the culprits and take appropriate steps to ensure that the guilty is punished in accordance with law.

Issue for consideration

Whether the complaint of kidnapping of a 15-year-old girl, which lay unregistered at Ram Krishna Nagar Police Station for about two months, required registration as an FIR and action towards recovery of the victim. +2 more

Court's answer

The writ application is disposed of as it has served its utility, the FIR having already been registered and the victim having been recovered.

Ratio / Principle

A direction is issued to the investigating agency to conclude the investigation of the case, nab the culprits and take appropriate steps to ensure that the guilty is punished in accordance with law.

Key takeaways

The Court found that, although it had been given to understand that a preliminary inquiry was ordered, there was in fact no preliminary inquiry in the matter.obiter¶18

Detailed headnote1 paragraphs

Criminal Writ Jurisdiction (Patna High Court, CR. WJC No.1083 of 2026, decided 07-07-2026; Rajeev Ranjan Prasad & Kumar Manish JJ, per Rajeev Ranjan Prasad J) — Kidnapping of a 15-year-old girl — complaint lay unregistered at Ram Krishna Nagar Police Station, Patna for about two months with no action towards recovery — by order dated 15.06.2026 the Court called upon the SSP, Patna and the SHO to file affidavits explaining the SHO's conduct in not registering the FIR — FIR registered the very next day — victim girl recovered — Court recorded that, despite representation to the contrary, no preliminary inquiry was conducted, and passed order dated 29.06.2026 — learned AG submitted that the SSP, Patna had taken appropriate steps — writ application disposed of as having served its utility, with a direction to the investigating agency to conclude the investigation, nab the culprits and ensure the guilty is punished in accordance with law.

IN THE HIGH COURT OF JUDICATURE AT PATNA Criminal Writ Jurisdiction Case No.1083 of 2026

======================================================

Pramila Devi @ Parmila Devi W/O Ashok Kumar R/o- Old Police line, 142 da Targhat, Police Station- Gandhi Maidan, District- Patna (Bihar). Pin Code800001

... ... Petitioner

Versus

The State of Bihar through the Director General of Police, Sardar Patel Bhawan, Bailey Road, Patna (Bihar). Pin Code- 800023

The Senior Superintendent of Police (S.S.P), District - Patna (Bihar). Pin Code-800001

The Station House Officer (S.H.O), Police Station - Ramakrishna-nagar, District- Patna (Bihar). Pin Code- 800025

... ... Respondents

====================================================== Appearance : For the Petitioner : Mr. Birendra Kumar, Advocate Mr. Rajiv Ranjan Singh, Advocate Mr. Mukesh Kumar Bhagat, Advocate For the Respondents : Mr. S D Sanjay, AG Mr. Sarvesh Kr Singh, AAG-13 Ms. Priya Gupta, AC to AG Mr. Shashwat Agarwal, AC to AG ======================================================

CORAM: HONOURABLE MR. JUSTICE RAJEEV RANJAN PRASAD and HONOURABLE MR. JUSTICE KUMAR MANISH ORAL ORDER

(Per: HONOURABLE MR. JUSTICE RAJEEV RANJAN PRASAD)

5 07-07-2026 Heard learned counsel for the petitioner and learned

AG for the State.

2. It appears from the previous orders passed by this Court that a 15 years old girl had been kidnapped but the complaint made in this regard was not registered in the Ram Krishna Nagar Police Station despite a lapse of about two months and no action was taken towards recovery of the victim girl.

Patna High Court CR. WJC No.1083 of 2026(5) dt.07-07-2026 2/3

3. After this Court passed the order on 15.06.2026 calling upon the Senior Superintendent of Police, Patna and the Station House Officer, Ram Krishna Nagar Police Station to file their respective affidavits explaining the conduct of the SHO in not registering the FIR and not taking any action in the matter, on the very next day, the FIR was registered.

4. This Court was informed that the victim girl has been recovered. This Court has recorded the statements made in the affidavit wherein this Court was given to understand that a preliminary inquiry was ordered in the matter which took some time but ultimately, the Court found that there was no preliminary inquiry in the matter. Keeping in view the same, this Court passed the order dated 29.06.2026.

5. Today, learned AG for the State submits that the Senior Superintendent of Police, Patna has taken appropriate steps in the light of the order of this Court.

6. Having regard to the fact that the present case has served its utility, FIR has already been registered and the victim has been recovered, so far this writ application is concerned, it is being disposed of with a direction to the investigating agency to conclude the investigation of the case, nab the culprits and take appropriate steps to ensure that the guilty is punished in

Patna High Court CR. WJC No.1083 of 2026(5) dt.07-07-2026 3/3

accordance with law.

7. This writ application stands disposed of

accordingly.

(Rajeev Ranjan Prasad, J)

(Kumar Manish, J)

lekhi/-praphul/-

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