2026 Supreme(Online)(Pat) 12883
PATNA HIGH COURT
Rani @ Rani Tiwari
CWJC-20071/2025
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
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; ykds vnkyr eas yafcr iqjkus pkykukas ls lacaf/kr foLr`r izfrons u@vfHkys[k ds lkFk ftykokj jk"Vªh; ykds vnkyr eas Hkkx yus s ,oa jk"Vªh; ykds vnkyr esa pkyku ls lacaf/kr gq, ekeykas dh lquokbZ@fu.k;Z ls lacaf/kr okguokj foLr`r lwph lfgr izfrons u 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:-
“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 Gener