Patna High Court

Manoj ManjhiversusThe State of Bihar

Decided: 23 February 2026
Disposal: ALLOWED
Bench: SANDEEP KUMAR

Holding

The court held that, on the petitioner's application and counsel's submission, it may extend the surrender period under the anticipatory bail order.

Summary

Manoj Manjhi was granted anticipatory bail on 23 December 2025 by the Patna High Court, with a direction to surrender within four weeks. He filed an application seeking modification of that order to obtain a further extension of the surrender period. The petitioner’s counsel argued for the extension, and the State did not oppose the request. The Court, after hearing both sides, allowed the application and extended the surrender deadline by an additional four weeks from 23 February 2026. Consequently, the original order was modified to reflect the new surrender timeline.

Issues considered

Whether the court may extend the surrender period prescribed in an anticipatory bail order under Section 438 of the Criminal Procedure Code

Subjects

anticipatory bail
surrender period
bail modification
CrPC Section 438
criminal procedure

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.12917 of 2026
                                              In
                              CRIMINAL MISCELLANEOUS No.89469 of 2025
                       Arising Out of PS. Case No.-331 Year-2017 Thana- PIRBAHOR District- Patna
                 ======================================================
                 Manoj Manjhi S/O Late Mithu Manjhi Resident of Mohalla -Bhanwar Pokhar
                 Jhoparpatti, Arya Kumar Road, P.S.- Pirbahore, District- Patna.

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s    :        Mr.Ravi Shanker Pankaj, Advocate
                 For the State           :        Ms.Sharda Kumari, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE SANDEEP KUMAR
                                       ORAL ORDER

2   23-02-2026                   Heard learned counsel for the petitioner and learned

                   counsel for the State.

                                 2. The present application has been filed for

                   modification of the order dated 23.12.2025 passed in Cr. Misc.

                   No. 89469 of 2025 by which the petitioner had been granted

                   anticipatory bail by this Court and he was directed to surrender

                   within four weeks from the date of the order.

                                 3. Considering the aforesaid submission of learned

                   counsel for the petitioner, this application is allowed.

                                 4. The time granted to the petitioner to surrender

                   before the Court below for furnishing the bail bonds vide order

                   dated 23.12.2025 passed in Cr. Misc. No. 89469 of 2025, is

                   hereby extended for a further period of four weeks from today.
           Patna High Court CR. MISC. No.12917 of 2026(2) dt.23-02-2026
                                                       2/2




                                  5. Accordingly, the order dated 23.12.2025 passed in

                     Cr. Misc. No. 89469 of 2025 is modified to the above extent.


                                                                          (Sandeep Kumar, J)

P. Kumar

U     T

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