The Patna High Court in 2025 underscored that justice demands adherence to proper statutory remedies, misuse of contempt or revision jurisdiction is impermissible, disciplinary action must rest on due process and evidence, matrimonial disputes are essentially private and should not be mechanically criminalised, pensionary benefits cannot be denied due to administrative lapses, and third parties cannot obstruct or delay settled civil proceedings by asserting independent claims.
Important Judgments of Patna High Court (2025)
Legal Bites Year Update
1) Complainant Cannot File Revision Against Summoning Order Under BNSS
The Patna High Court, in Laxmi Devi @ Suman Devi v. State of Bihar (2025), held that a complainant cannot file a criminal revision under Section 438 of the Bharatiya Nagarik Suraksha Sanhita, 2023 against a summoning order, as such an order is interlocutory in nature for the complainant. The Court clarified that even if revision succeeds by adding more accused or offences, the proceedings would continue and not terminate, whereas for the accused, the same order is intermediate, since its setting aside would end proceedings against them.
Accordingly, the revision was dismissed as not maintainable, with liberty to the complainant to invoke inherent powers under Section 528 BNSS or seek summoning of additional accused during trial under Section 358 BNSS, if supported by evidence.
2) Medical Emergency Justifies Absence; Wilful Misconduct Not Presumed
The Patna High Court, in Manoj Kumar Yadav v. State of Bihar & Ors. (2025), set aside the termination of a Panchayat Rojgar Sevak under MGNREGA, holding that absence from duty due to compelling personal circumstances cannot be treated as wilful misconduct without proper inquiry. The Court found that the petitioner’s contract was terminated solely on the allegation of unauthorised absence, despite evidence showing that he had applied for leave owing to his mother’s serious heart ailment and hospitalisation.
Relying on settled Supreme Court precedents, the High Court held that absence must be proved to be wilful and that termination without following prescribed disciplinary guidelines, issuing a proper show-cause notice, and granting an opportunity of hearing violates principles of natural justice.
Consequently, the termination order, appellate and revisional orders were quashed, and the respondents were directed to reinstate the petitioner with all consequential benefits.
3) Private Matrimonial Disputes Cannot Be Treated as Societal Offences
The Patna High Court, in Akash Kumar & Ors. v. State of Bihar & Anr. (2025), held that matrimonial disputes arising from allegations of cruelty and dowry demand registered under Sections 498A/34 IPC corresponding to Section 85 read with Section 3(5) of the Bharatiya Nyaya Sanhita, 2023 and Sections 3 and 4 of the Dowry Prohibition Act are essentially private in nature and that relatives of the husband should not be mechanically implicated.
Observing the parties’ willingness to resolve the dispute amicably, the Court quashed the criminal proceedings against the father-in-law, mother-in-law and brother-in-law, directed the husband and wife to participate in mediation, and granted interim protection from coercive action, reiterating that continuation of criminal prosecution without clear criminal content would amount to abuse of the process of law.
4) Widow of Temporary Status Postal Worker Entitled to Family Pension
The Patna High Court, in Union of India & Ors. v. Bindi Devi (2025), dismissed the Union of India’s challenge to the CAT order granting family pension and retiral benefits to the widow of a deceased postal employee who had been conferred temporary status but was never formally regularised. The Court held that once a casual labourer attains temporary status and completes the requisite service, the denial of pensionary benefits due to the department’s failure to regularise cannot prejudice the employee or his family.
Relying on principles of beneficial and harmonious construction and earlier coordinate bench decisions, the Court affirmed that the respondent was entitled to family pension, arrears, and interest, and upheld the CAT’s directions for payment within the stipulated time.
5) State Not Bound by Advocate’s Unauthorised Concession
The Patna High Court, in State of Bihar v. Arena Food and Agro Industries Pvt. Ltd. (2025), held that the State cannot be bound by a concession made by its advocate without express instructions from the concerned department. The Court observed that an advocate has no implied authority to agree to proposals or settlements affecting substantive rights unless duly authorised.
Since the earlier judgment was based on an unauthorised concession by the advocate for the Mines Department, the Division Bench set it aside and remitted the matter to the Single Judge for fresh adjudication on the merits after hearing both sides, directing the maintenance of the status quo until then.
6) Departmental Dismissal Cannot Be Based Solely on FIR Without Witnesses
The Patna High Court, in Chandra Bhushan Pravin v. State of Bihar & Ors. (2025), set aside the dismissal of a Revenue Clerk accused of accepting a bribe, holding that a departmental enquiry cannot rest merely on an FIR and documentary material without examination of witnesses. The Court found that no complainant, trap team member, or independent witness was examined, in violation of the Bihar Government Servants (Classification, Control & Appeal) Rules, 2005 and principles of natural justice.
Relying on settled Supreme Court precedents, the Court ruled that even in departmental proceedings, charges of demand and acceptance of bribe must be supported by some legal evidence. Consequently, the dismissal and appellate orders were quashed, the petitioner was directed to be reinstated, with liberty to the State to proceed afresh depending on the outcome of the criminal case.
7) Intervenor Cannot Be Impleaded to Assert Independent Title in Partition Suit
In Nandu Singh alias Nand Kishore Singh & Ors. v. Amrendra Bhushan Bhardwaj & Ors. (2025), the Patna High Court held that third parties claiming an independent right, title, and possession over one of the properties included in a partition suit are neither necessary nor proper parties to such proceedings. The Court clarified that a partition suit is confined to division among co-sharers and the trial court is not expected to adjudicate the title of intervenors.
Observing that the suit had been pending since 1994 and had culminated in a compromise, the Court emphasised the principles of dominus litis and finality of settlement, ruling that permitting impleadment at this stage would only delay proceedings. The High Court affirmed that the intervenors were free to pursue their remedies through an independent suit, and accordingly dismissed the petition challenging the rejection of their impleadment application.
8) Challenge to EPF Assessment Lies in Appeal, Not Contempt Proceedings
The Patna High Court, in Raj Kumar Gupta v. The Regional Provident Fund Commissioner Employees And Ors. (2025), dismissed a contempt petition alleging non-compliance of earlier writ directions concerning EPF assessment, holding that the authorities had already complied by passing a consolidated assessment order dated 28 March 2018 in line with Food Corporation of India v. Provident Fund Commissioner.
The Court noted that the petitioner, instead of challenging the assessment through the statutory appellate remedy, repeatedly invoked contempt jurisdiction despite being aware that reassessment for both disputed periods had been completed. Terming the petition frivolous and an abuse of process, the Court dismissed it with costs of ₹25,000 payable to the respondent authorities.
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