Patna High Court

Sanjiv Ray @ Sanjeev Ranjan KumarversusThe State of Bihar

Decided: 13 February 2026
Disposal: ALLOWED
Bench: KHATIM REZA

Holding

The modification application is allowed, the alias name is incorporated in the cause title, and a four‑week extension for surrender is granted.

Summary

The petitioner, Sanjiv Ray, filed an anticipatory bail application (Cr. Misc. No.89014 of 2025) but his Aadhar card listed his name as Sanjeev Ranjan Kumar, creating a discrepancy that prevented him from surrendering as ordered. He applied to the Patna High Court for modification of the earlier bail order to incorporate his alias name in the cause title and to obtain additional time to surrender before the lower court. The court examined whether such a procedural modification and time extension were permissible. It held that the alias could be added to the cause title and granted a further four weeks for surrender. Consequently, the modification application was allowed, and the order dated 23.12.2025 was amended accordingly.

Issues considered

Whether the High Court can modify the cause title of an anticipatory bail order to include an alias name of the petitioner.
Whether the High Court can extend the time for the petitioner to surrender before the lower court.

Subjects

anticipatory bail
modification of order
alias name
cause title
surrender
procedural law
bail extension

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.11232 of 2026
                                              In
                              CRIMINAL MISCELLANEOUS No.89014 of 2025
                      Arising Out of PS. Case No.-509 Year-2025 Thana- VAISHALI District- Vaishali
                 ======================================================
                 Sanjiv Ray @ Sanjeev Ranjan Kumar aged about 38 years, male, S/o- Jiyalal
                 Ray @ Jiyalal Prasad Yadav, resident of Village- Mohammadpur, PS- Paroo,
                 Dist- Muzaffarpur
                                                                            ... ... Petitioner/s
                                                   Versus
                 The State of Bihar
                                                                     ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :       Mr. Anish Kumar, Advocate
                 For the Opposite Party/s :       Mr. Ajit Kumar, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE KHATIM REZA
                                       ORAL ORDER

2   13-02-2026                  Heard learned counsel for the parties.

                                2. This application has been filed for modification of

                   the order dated 23.12.2025 passed in Cr. Misc. No.89014 of

                   2025 by which the petitioner was granted bail in Vaishali PS

                   Case No.509 of 2025 to the satisfaction of the Exclusive Special

                   Excise Court No.II cum Additional District & Sessions Judge,

                   Vaishali at Hajipur.

                                3. Learned counsel for the petitioner submits that the

                   petitioner had filed Cr. Misc. No.89014 of 2025 for grant of

                   anticipatory bail with his name as Sanjiv Ray, however, in the

                   Aadhar Card of the petitioner, his name has been written as

                   ‘Sanjeev Ranjan Kumar’ and due to discrepancy in the name of

                   the petitioner, he could not surrender before the Court below.

                   Learned counsel for the petitioner seeks permission that he may
            Patna High Court CR. MISC. No.11232 of 2026(2) dt.13-02-2026
                                                        2/2




                      be permitted to add his alias name as ‘Sanjeev Ranjan Kumar’

                      in the cause title of Cr. Misc. No.89014 of 2025 along with

                      ‘Sanjiv Ray’ and four weeks’ time may be extended to surrender

                      before the Court below in compliance of order dated 23.12.2025

                      passed in Cr. Misc. No.89014 of 2025.

                                   4. Permission is granted. Let the alias name of the

                      petitioner i.e., ‘Sanjeev Ranjan Kumar’ be incorporated in the

                      cause title of Cr. Misc. No.89014 of 2025 in course of the day.

                                   5. Accordingly, in the case title of order dated

                      23.12.2025 passed in Cr. Misc. No.89014 of 2025, name of the

                      petitioner be read as “Sanjiv Ray @ Sanjeev Ranjan Kumar” in

                      place of ‘Sanjiv Ray’.

                                   6. Four weeks’ further time from today is granted to

                      the petitioner to surrender before the Court below in compliance

                      of order dated 23.12.2025 passed in Cr. Misc. No.89014 of

                      2025.

                                   7. The cause title of the order dated 23.12.2025 passed

                      in Cr. Misc. No.89014 of 2025 stands modified to the aforesaid

                      extent.

                                   8. This modification application stands allowed


                                                               (Khatim Reza, J)
J. Alam/-
U       T

Continue reading with your account

Checking your session…