Patna High Court

Golden KumarversusThe State of Bihar

Decided: 16 February 2026
Disposal: DISMISSED
Bench: SATYAVRAT VERMA

Holding

The court held that an anticipatory bail order will not be modified even if it was obtained by concealing the petitioner’s criminal antecedents.

Summary

Golden Kumar, the petitioner, had earlier been granted anticipatory bail. He later applied to have that bail order modified, alleging that the original order was obtained by concealing his criminal antecedents. The State opposed the modification. Justice Satyavrat Verma, adhering to a consistent judicial approach, held that an anticipatory bail order should not be altered merely because the petitioner concealed prior criminal history. Consequently, the application to modify the anticipatory bail was rejected, leaving the original bail order intact.

Issues considered

Whether an anticipatory bail order can be modified or cancelled on the ground that it was obtained by concealing the petitioner’s criminal antecedents

Subjects

anticipatory bail
modification
concealment of antecedents
Criminal Procedure Code
high court

Judgment

                       IN THE HIGH COURT OF JUDICATURE AT PATNA
                               CRIMINAL MISCELLANEOUS No.11234 of 2026
                                               In
                               CRIMINAL MISCELLANEOUS No.57183 of 2025
                       Arising Out of PS. Case No.-490 Year-2025 Thana- AMARPUR District- Banka
                  ======================================================
                  Golden Kumar S/o- Mohan Yadav Resident of village-Fullidumar Ps-
                  Fullidumar District- Banka

                                                                                  ... ... Petitioner/s
                                                       Versus
                  The State of Bihar

                                                         ... ... Opposite Party/s
                  ======================================================
                  Appearance :
                  For the Petitioner/s     :      Mr. Sudhir Kumar Mishra, Advocate
                  For the Opposite Party/s :      Mr. Ajay Kumar No. 2, APP
                  ======================================================
                  CORAM: HONOURABLE MR. JUSTICE SATYAVRAT VERMA
                                        ORAL ORDER

2    16-02-2026                      1. Heard learned counsel for the petitioner and the

                    learned APP for the State.

                                       2. The Court is taking a consistent view of not

                    modifying the order by which anticipatory bail was granted to

                    the petitioner, if the same was obtained by concealing criminal

                    antecedent.

                                    3. The modification application is rejected.



                                                     (Satyavrat Verma, J)
Rishabh/-

U      T

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