Patna High Court

Jayant KumarversusThe State of Bihar

Decided: 11 February 2026
Disposal: DISMISSED
Bench: PRABHAT KUMAR SINGH

Holding

A second anticipatory bail petition is not maintainable.

Summary

The petitioner, Jayant Kumar, filed a second anticipatory bail petition after an earlier one was withdrawn. The court noted that the current petition did not demonstrate any change in circumstances or new grounds. Relying on the Supreme Court's decision in G.R. Ananda Babu v. State of Tamil Nadu (2021 SCC OnLine SC 176), the judge held that a second anticipatory bail application is not maintainable. Consequently, the petition was dismissed. No other substantive arguments or evidence were presented to alter the earlier position.

Issues considered

Is a second anticipatory bail petition maintainable in the absence of changed circumstances?
Does the Supreme Court precedent in G.R. Ananda Babu v. State of Tamil Nadu preclude a second anticipatory bail application?

Subjects

anticipatory bail
second petition
maintainability
Supreme Court precedent
criminal procedure

Judgment

                       IN THE HIGH COURT OF JUDICATURE AT PATNA
                                CRIMINAL MISCELLANEOUS No.1596 of 2026
                        Arising Out of PS. Case No.-483 Year-2025 Thana- DANAPUR District- Patna
                  ======================================================
                  Jayant Kumar S/o Jitendra Vishwakarma @ Jitendra Kumar Vishwakarma R/o
                  vill - Saguna, Naya Tola, P.s.- Danapur, Distt.- Patna

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

                                                         ... ... Opposite Party/s
                  ======================================================
                  Appearance :
                  For the Petitioner/s     :       Mr. Ramakant Sharma, senior Advocate
                                                   Mr. Rakesh Kumar sharma, Advocate
                                                   Mr. Santosh Kumar Pandey, Advocate
                  For the Opposite Party/s :       Mr. Sanjay Kumar Tiwary, APP
                  ======================================================
                  CORAM: HONOURABLE MR. JUSTICE PRABHAT KUMAR SINGH
                                        ORAL ORDER

2    11-02-2026                     Heard learned counsel for the parties.
                                  2. This is second anticipatory bail petition. Earlier, the
                    petition, filed for grant of anticipatory bail on behalf of
                    petitioner, stood dismissed as withdrawn , vide order dated
                    20.08.2025 passed in Cr. Misc. No. 52821 of 2025 .
                                  3 . This application does not reveal any change of
                    circumstances or new ground.
                                   4. In view of the recent judgment of the Hon’ble
                    Supreme Court in the case of G.R. Ananda Babu Vs. State of
                    Tamil Nadu and Anrs reported in 2021 SCC OnLine SC 176,
                    the second anticipatory bail on behalf of the petitioner is not
                    maintainable. It is, accordingly, dismissed.



                                           (Prabhat Kumar Singh, J)
Koushik/-

U      T

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