Patna High Court

Naushad AliversusThe State of Bihar

Decided: 11 February 2026
Disposal: BAIL REJECTED
Bench: PRABHAT KUMAR SINGH

Holding

A second anticipatory bail petition is not maintainable without a change of circumstances.

Summary

The petitioner, Naushad Ali, filed a second anticipatory bail petition after an earlier petition was rejected on 25‑11‑2025. The court noted that the new application did not demonstrate any change in circumstances or present any fresh ground for relief. 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 petition is not maintainable. Consequently, the petition was dismissed. No other substantive arguments or evidence were considered.

Issues considered

Whether a second anticipatory bail petition can be entertained in the absence of a change of circumstances
Whether the Supreme Court’s precedent on the non‑maintainability of successive anticipatory bail applications applies

Subjects

anticipatory bail
second petition
change of circumstances
Criminal Procedure Code
bail jurisprudence

Judgment

                       IN THE HIGH COURT OF JUDICATURE AT PATNA
                               CRIMINAL MISCELLANEOUS No.2210 of 2026
                         Arising Out of PS. Case No.-226 Year-2025 Thana- BUXAR District- Buxar
                  ======================================================
                  Naushad Ali son of Late Saukat Ali Resident Of Village -Bali Tola, Ps -Buxar,
                  Dist -Buxar

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

                                                         ... ... Opposite Party/s
                  ======================================================
                  Appearance :
                  For the Petitioner/s     :       Mr. Sunil Kumar , Advocate
                  For the Opposite Party/s :       Mr. Aditya Narayan Singh 1, 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 rejected, vide order dated 25.11.2025 passed
                    in Cr. Misc. No. 56287 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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