Patna HC Directs Three-Member Committee to Identify Left-Out Muzaffarpur Farmers for Kharif 2025 Crop Loss Compensation
The Patna High Court, invoking Articles 14 and 21, pressed Bihar's Agriculture Department to reach farmers who missed the DBT portal deadline for Kharif 2025 crop damage relief.
A Division Bench of the Patna High Court, comprising the Chief Justice Sangam Kumar Sahoo and Justice Harish Kumar, on 14 May 2026 took up the sixth listing of Sanjay Kumar v The State of Bihar & Ors. (CWJC No. 3121 of 2026) and directed Bihar's Agriculture Department to complete field verification of residual Kharif 2025 crop-loss claims in Muzaffarpur district. The bench had earlier invoked Articles 14 and 21 of the Constitution, holding that denial of relief after an assessed crop loss infringes the right to livelihood of affected farmers. With over 1,11,861 farmers already compensated and Rs. 33,25,04,753 disbursed through the Direct Benefit Transfer mechanism, the court's concern now centres on those who could not apply through the portal before it closed on 2 December 2025.
How the Matter Reached This Stage
The crop damage assessment for Kharif 2025 in Muzaffarpur district was completed and forwarded to the State Government by the District Magistrate, Muzaffarpur, vide Letter No. 3413 dated 5 December 2025. That letter set out the total area of land affected, the crops damaged, and a provisional compensation figure. The DBT-based application portal under the agricultural input subsidy scheme had, however, closed on 2 December 2025, three days before the district's own assessment letter reached the Director, Agriculture Department, Bihar, Patna.
When the matter was heard on 12 May 2026, the District Magistrate informed the court that action on the portal was expected at the level of the Agriculture Department, but none had been taken. The Director's stated reason was that the Rabi season had already commenced in the meantime. The bench found this unsatisfactory and directed the Director to appear through virtual mode on the next date and to furnish, in writing, the ways and means by which farmers who had sustained crop loss could conveniently receive compensation without hindrance.
The Director's Written Mechanism
In compliance with that direction, the Director, Agriculture, Bihar, submitted a report dated 13 May 2026 setting out a six-step disbursement mechanism. The report acknowledged that compensation had already been paid to farmers who applied within the prescribed timeline and were found eligible. It identified two categories of residual cases: farmers who did not submit applications within the deadline, and those affected by procedural limitations in the digital framework.
To address these residual cases, the Director constituted a three-member committee vide Office Order dated 13 May 2026. The committee's mandate covers field verification in affected panchayats, identification of unattended claims, and submission of a report within 15 days. After the committee reports, the State Government is to examine the feasibility of extending benefit, keeping in view financial provisions and permissibility under existing scheme guidelines, before taking a final decision.
The report also included what it called “clarificatory safeguards,” stating that the scheme is inherently time-bound and that no automatic or open-ended entitlement arises beyond the prescribed framework. It added, however, that the exercise was being undertaken in deference to the court's observations so that genuine eligible cases are not left unexamined.
Scale of Disbursement Already Made
On a query from the bench, the Director disclosed that 1,11,861 farmers had been compensated for Kharif 2025 crop damage on the basis of applications submitted through the portal. The total amount disbursed stands at Rs. 33,25,04,753. The Director also stated that awareness programmes were conducted at the village level through village-level workers and Kisan Salahkars, and that a communique was published in local daily newspapers on 15 November 2025 to inform farmers about the application process.
The Bench's Reasoning on Articles 14 and 21
The bench noted that it had invoked Articles 14 and 21 of the Constitution in its earlier order dated 2 May 2026, holding that denial of relief after an assessed crop loss infringes the right to livelihood of affected farmers. The court stated plainly that “the farmer who feeds the entire nation cannot be left to fend for himself when natural disaster strikes his field.”
Against that constitutional backdrop, the bench read the Director's report as a positive step but made clear that the exercise must be genuine. It recorded its expectation that if farmers are found eligible upon field verification, necessary steps shall be taken expeditiously and strictly in accordance with law. The court also directed the District Administration to undertake proper awareness measures so that left-out farmers appear before the three-member committee for verification.
The bench separately directed that the committee must also take into account Letter No. 3413 dated 5 December 2025, the District Magistrate's original crop damage report, which contains ownership details of the concerned farmers. This direction is significant because the Rabi season has already commenced, meaning the committee will need to cross-reference the earlier Kharif assessment rather than conduct a fresh seasonal survey.
Directions and Next Steps
The bench directed the Director, Agriculture Department, Bihar, to file a further affidavit by the next date disclosing: the number of residual or unattended cases identified by the three-member committee; the extent of crop loss in each such case; and the disbursement of compensation, if any, made in favour of eligible left-out farmers. A copy of the affidavit is to be furnished to the petitioner's counsel in advance.
The District Magistrate, Muzaffarpur, the District Agriculture Officer, Muzaffarpur, and the Block Development Officer, Sahebganj, Muzaffarpur, are directed to join the proceedings through virtual mode on the next date along with the Director, Agriculture Department, Bihar.
Order
The matter is listed for 24 June 2026 at 11:00 A.M. The three-member committee constituted on 13 May 2026 is to submit its report to the Director, Agriculture Department, Bihar, within 15 days of its constitution. The Director is to file the compliance affidavit before the next date. A free copy of the order was directed to be handed over to the counsel for the State.
Petitioner Sanjay Kumar is represented by Mr. Abhay Kumar Mishra, Mr. Sonu Singh, and Mr. Sarfraz Ahmad. The State of Bihar is represented by Mr. Vikash Kumar, Additional Counsel to the Advocate General.