In a significant judgment reinforcing the sanctity of personal liberty, the Patna High Court has ordered the Bihar State Government to pay ₹5 lakh in compensation to a 15-year-old boy who was illegally detained for two and a half months.

A Division Bench comprising Justice Rajeev Ranjan Prasad and Justice Ritesh Kumar held that the minor’s fundamental rights were flagrantly violated by police officials who ignored established legal procedures. Crucially, the Court directed that the compensation amount be recovered from the personal salaries of the police officers found responsible for the lapse.

The case originated from a land dispute in a village under the jurisdiction of Puraini Police Station. The teenage petitioner, along with several others, was accused of assault during a village Panchayati meeting.

During the initial investigation, the police filed a chargesheet. However, the Investigating Officer (IO) found insufficient evidence against the 15-year-old boy and nine others, and they were subsequently excluded from the trial list. For all legal purposes, the boy was no longer an accused in the eyes of the law.

The situation took a sharp turn when the Deputy Inspector General of Police (DIG) office issued a "supervision note." This note directed the IO to proceed as if the allegations against the excluded individuals were true. Acting on this note—and without seeking fresh evidence or the permission of a Magistrate—the police conducted a raid in October 2025 and arrested the teenager.

The petitioner’s counsel, advocates Shashwat Kumar, Aman Alam, and Amarnath Kumar, argued before the High Court that the arrest was entirely unlawful. They pointed out two major failures:

Procedural Lapse: The IO arrested the boy after the chargesheet had already been filed without obtaining a warrant or permission from a Magistrate.
Juvenile Justice Violation: Despite a Bihar School Examination Board certificate proving the boy was only 15 years and 6 months old at the time of the incident, he was treated as an adult and sent to a regular jail instead of being produced before a Juvenile Justice Board (JJB).

It was only after a writ petition was filed in the High Court that the lower court Magistrate finally referred the boy to the JJB.

The High Court expressed its deep displeasure at the conduct of the Bihar Police. The Bench noted that the liberty of a citizen cannot be curtailed on the mere whims of a supervision note if the legal requirements for an arrest are not met.

"This Court is fully satisfied that the liberty of the petitioner in the present case has been curtailed and his Right to Life and Liberty has been violated by the act of the police officials," the Bench observed.

The judges emphasized that as a Constitutional Court, they could not remain a "mute spectator" when a young boy is subjected to physical and mental agony due to systemic negligence.

To ensure accountability and provide relief to the victim, the High Court issued the following orders:

Financial Compensation: The State of Bihar must pay ₹5,00,000 (Five Lakhs) to the petitioner within one month. This amount is intended to compensate for the "physical and mental agony" suffered during his 75-day illegal detention.
Litigation Costs: The State must also pay ₹15,000 to the family to cover the costs of the legal battle.
Accountability for Officers: The Court directed the Director General of Police (DGP), Bihar, to conduct an administrative inquiry. The compensation paid by the State is to be recovered from the erring police officers' salaries once the responsibility is fixed.
Immediate Release: The Court ordered the prompt release of the teenager from custody.

This ruling serves as a stern warning to law enforcement agencies regarding the misuse of power. It highlights that "Supervision Notes" from senior officials do not override the Code of Criminal Procedure (CrPC) or the Juvenile Justice Act.

By ordering the recovery of the compensation from the officers' own pockets, the Patna High Court has sent a clear message: police officers will be held personally and financially liable for violating the constitutional rights of citizens.

The State was represented in the matter by Mr. P.N. Sharma, Additional Counsel to the Attorney General.

Case Details: M.J. (Minor) vs. The State of Bihar & Anr.

Case No: CR. WJC No. 3077 of 2025

Date of Order: January 9, 2026