Patna High Court

Lal Mohan RaiversusThe State of Bihar

Decided: 20 April 2026
Disposal: DISPOSED
Bench: SATYAVRAT VERMA

Holding

The Court held that the anticipatory bail order could be modified to accurately reflect the petitioner’s eleven pending cases under the Excise Act.

Summary

The petitioner, Lal Mohan Rai, had been granted anticipatory bail on 20 April 2026. He later pointed out that the order incorrectly stated that he had nine pending cases under the Excise Act, whereas the application disclosed eleven such cases. He sought a modification of paragraphs 3 and 6 of the bail order to reflect the correct number of cases. The Court examined the petitioner's submission and agreed that the factual error needed correction. Accordingly, the Court modified the order to read eleven cases under the Excise Act in paragraph 3 and to reflect more than eleven cases in paragraph 6. The modification was entered without altering any other conditions of the anticipatory bail.

Issues considered

Whether a court may modify an anticipatory bail order to correct factual inaccuracies regarding the number of pending cases
Whether the correction of the antecedent case count affects the validity of the bail order

Legislation cited

Excise Act

Subjects

anticipatory bail
modification of order
Excise Act
criminal procedure
pending cases

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.24576 of 2026
                       Arising Out of PS. Case No.-198 Year-2026 Thana- SONEPUR District- Saran
                 ======================================================
                 Lal Mohan Rai S/o Ram Badan Rai R/V Baburbani, P.S-Sonepur, Dist-Saran

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :       Mr.Sanjeet Kumar Singh
                 For the Opposite Party/s :       Mr.Khurshid Anwar
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE SATYAVRAT VERMA
                                       ORAL ORDER

3   22-04-2026                  1. Heard learned counsel for the petitioner and

                   learned APP for the State.

                                2. The learned counsel for the petitioner submits that

                   petitioner was granted the privilege of anticipatory bail by an

                   order dated 20.04.2026 but then at Para-3, it has been recorded

                   that petitioner has antecedent of nine cases when petitioner has

                   antecedent of eleven cases under the Excise Act as pleaded at

                   Para-3 of the anticipatory bail application. The learned counsel

                   thus seeks permission to modify the Para-3 and Para-6 of the

                   order dated 20.04.2026.

                                3. In view of the submissions made by the learned

                   counsel appearing on behalf of the petitioner at Para-3, nine

                   cases under the Excise Act would be read as eleven cases under

                   the Excise Act and at Para-6 it would be read more than eleven
               Patna High Court CR. MISC. No.24576 of 2026(3) dt.22-04-2026
                                                           2/2




                         cases instead of nine cases.

                                      4. The order dated 20.04.2026 is modified to the

                         extent as indicated above.



                                                   (Satyavrat Verma, J)
vikash/-

U          T

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