Patna High Court – Orders
Rani @ Rani Tiwari vs The State Of Bihar on 11 March, 2026
Author: Alok Kumar Sinha
Bench: Alok Kumar Sinha
IN THE HIGH COURT OF JUDICATURE AT PATNA
Civil Writ Jurisdiction Case No.20071 of 2025
======================================================
Rani @ Rani Tiwari
... ... Petitioner
Versus
The State of Bihar & Ors.
... ... Respondents
======================================================
Appearance :
For the Petitioner/s : Mr. Vikash Kumar Pankaj, Advocate
For the Respondent/s : Mr. P.K. Shahi, Advocate General
Mr. P.K. Verma, Sr. Advocate, AAG-3
Mr. Sanjay Kumar Ghosarvey, AC to AAG-3
======================================================
CORAM: HONOURABLE THE CHIEF JUSTICE
and
HONOURABLE MR. JUSTICE ALOK KUMAR SINHA
ORAL ORDER
(Per: HONOURABLE THE CHIEF JUSTICE)
4 11-03-2026
It is brought to our notice by the learned Member
Secretary, Bihar State Legal Services Authority (hereafter
‘BSLSA’) that he had earlier received a letter bearing Diary No.
2993 J/NALSA/LA-2025/345 dated 17.11.2025 from the
National Legal Services Authority (hereafter ‘NALSA’) along
with complaint regarding non-disposal of the traffic challan
cases in Lok Adalat in the State of Bihar, and in the light of the
said letter, he had issued a letter dated 18.11.2025 to the Law
Secretary, Law Department, Government of Bihar for taking up
the issues with the Transport Secretary and also requesting to
refer the matters related to traffic challans in the National Lok
Adalat which was at that time scheduled to be held on
Patna High Court CWJC No.20071 of 2025(4) dt.11-03-2026
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13.12.2025. With reference to the letter of BSLSA, a letter dated
25.11.2025 was sent by the Law Secretary to the Additional
Chief Secretary, Transport Department, Government of Bihar to
take necessary steps for disposal of cases relating to traffic e-
challans in the scheduled Lok Adalat as well as in the future
National Lok Adalats.
2. Though, no communication was received from the
Transport Department regarding the action taken, however, the
Member Secretary, who is present in Court, submits that today
he has received a letter dated 10.03.2026 through WhatsApp,
issued by the Officer on Special Duty, Transport Department,
Bihar, Patna addressed to all the District Transport Officers,
Bihar.
The Operative portion of the said letter, in verbatim,
reads as under:
“vr% vuqjks/k gS fd fnukad& 14-03-2026 dks
vk;ksftr gksus okys jk”Vªh; yksd vnkyr esa yafcr iqjkus
pkykuksa ls lacaf/kr foLr`r izfrosnu@vfHkys[k ds lkFk
ftykokj jk”Vªh; yksd vnkyr esa Hkkx ysus ,oa jk”Vªh;
yksd vnkyr esa pkyku ls lacaf/kr gq, ekeyksa dh
[email protected]; ls lacaf/kr okguokj foLr`r lwph lfgr
izfrosnu foHkkx dks miyC/k djkus dh d`ik dh tk;A”
The letter dated 10.03.2026 is taken on record.
3. Section 200(1) of the Motor Vehicles Act, 1988
reads as follows:-
Patna High Court CWJC No.20071 of 2025(4) dt.11-03-2026
3/5“200. Composition of certain offences. (1)
Any offence whether committed before or after
the commencement of this Act punishable
under section 177, section 177A, section 178,
section 179, section 180, section 181, section
182, sub-section (1) or sub-section (3) or sub-
section (4) of section 182A, section 182B, sub-
section (1) or sub-section (2) of section 183,
clause (c) of the Explanation to section 184,
section 186, section 189, sub-section (2) of
section 190, section 192, section 192A, sub-
section (3) of section 192B, section 194,
section 194A, section 194B, section 194C,
section 194D, section 194E, section 194F,
section 196, section 198 and section 201, may,
either before or after the institution of the
prosecution, be compounded by such officers
or authorities and for such amount as the
State Government may, by notification in the
Official Gazette, specify in this behalf.”
4. It is also brought to our notice that in the States of
Orissa, Gujarat and Delhi, notification under Section 200(1) of
the Motor Vehicles Act, 1988 has already been issued. This
provision empowers the officer or the authority entrusted by the
State Government by notification in the official gazette to
compound the offences either before or after institution of the
prosecution. It is stated at the Bar, which is also not disputed by
the learned Advocate General, that there is no such notification
in the State of Bihar in terms of Section 200(1) of the Motor
Vehicles Act, 1988.
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Let immediate steps be taken by the State
Government by publishing such notification indicating the
minimum amount by which such offences can be compounded
and by the authority who is competent to compound such
offences.
5. At this juncture, the learned Member Secretary,
BSLSA has apprised this Court that he had already
communicated to all the DLSA Secretaries to take up the matter
related to traffic challan in the upcoming National Lok Adalat
scheduled to be held on 14.03.2026.
It is expected that immediate steps shall be taken by
the Government and particularly the Respondent No. 4, the
Secretary, Department of Transport, Government of Bihar, Patna
to see that there is no hindrance in taking up the traffic challan
matters in the upcoming National Lok Adalat to be held on
14.03.2026. The learned Member Secretary shall work in
tandem with the Respondent No.4 to ensure proper mass
awareness among the public about such matters likely to be
taken up in the upcoming National Lok Adalat.
6. List this matter on 20.04.2026.
7. Learned Advocate General shall apprise this Court
about the development made in the meantime regarding the
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notification by the State Government in terms of Section 200(1)
of the Motor Vehicles Act, 1988.
(Sangam Kumar Sahoo, CJ)
(Alok Kumar Sinha, J)
shailendra/-
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