Patna High Court

Dr. Praveen Kumar SinhaversusThe State Of Bihar

Decided: 30 January 2026
Disposal: DISMISSED
Bench: SHAILENDRA SINGH

Holding

The petition was dismissed as infructuous because the order under review had become moot after the trial court disposed the case.

Summary

Dr. Praveen Kumar Sinha filed a petition under Section 227 of the Criminal Procedure Code seeking review of an order dated 10‑05‑2016 passed by the Additional Sessions Judge‑5th Lakhisarai, which had rejected his prayer. The trial court subsequently disposed of the case, rendering the order under review moot. The High Court examined whether the petition could still be entertained. It held that since the order had become infructuous, the petition could not proceed. Consequently, the petition was dismissed as being infructuous.

Issues considered

Whether a petition under Section 227 CrPC is maintainable when the order sought to be reviewed has become infructuous.

Legislation cited

Code of Criminal Procedure, 1973 — s. 227

Subjects

Criminal Procedure Code
Section 227
Review Petition
Infructuous Order
Dismissal

Judgment

                       IN THE HIGH COURT OF JUDICATURE AT PATNA
                               CRIMINAL MISCELLANEOUS No.26394 of 2016
                    Arising Out of PS. Case No.-443 Year-2014 Thana- LAKHISARAI District- Lakhisarai
                  ======================================================
                  Dr. Praveen Kumar Sinha

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

                                                         ... ... Opposite Party/s
                  ======================================================
                  Appearance :
                  For the Petitioner/s     :       Mr. Shama Sinha, Adv.
                  For the Opposite Party/s :       Mr.Sri Mujtabaul Haque, APP.
                  ======================================================
                  CORAM: HONOURABLE MR. JUSTICE SHAILENDRA SINGH
                                        ORAL ORDER

5    30-01-2026                    Mr. Shama Sinha learned counsel for the petitioner is

                    present.

                                 As per the office notes, the petitioner’s case has been

                    disposed of by the trial court hence the instant petition in which

                    the order dated 10.05.2016 passed by the learned Additional

                    Sessions Judge-5th Lakhisarai, in sessions trial no 25 of 2015

                    rejecting the prayer made by the petitioner under section 227 of

                    the Cr. P.C, has been impugned has become infructuous, so,

                    considering this aspect the instant petition stands dismissed as

                    being infructuous.



                                               (Shailendra Singh, J)
siddharthkr/-

U       T

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