Patna High Court
Anjay Kumar @ Manjay SahniversusThe State of Bihar
- Decided
- Disposal
- DISPOSED
- Bench
- SATYAVRAT VERMA
Holding
The Court may modify an anticipatory bail order to correct a clerical error, and therefore the order dated 28‑01‑2026 is amended to read Bhagwatpur Bhuski.
Summary
The petitioner, Anjay Kumar, applied for anticipatory bail under Section 30(a) of the Indian Penal Code. An order granting anticipatory bail was issued on 28‑01‑2026, but it incorrectly recorded his village as “Bhagwanpur Bhuski” instead of the correct “Bhagwatpur Bhuski”. The petitioner’s counsel highlighted this clerical mistake and sought a correction. The Court examined whether a judicial order could be modified to rectify such a typographical error. Relying on its inherent powers to correct clerical mistakes, the Court ordered that the village name be read as “Bhagwatpur Bhuski”. The remainder of the anticipatory bail order was left unchanged.
Issues considered
- Whether the anticipatory bail order can be corrected to rectify a clerical error in the description of the petitioner’s village?
Legislation cited
- Indian Penal Code — s. 30(a)
Subjects
- anticipatory bail
- clerical error
- order correction
- IPC Section 30
- criminal procedure
Judgment
IN THE HIGH COURT OF JUDICATURE AT PATNA
CRIMINAL MISCELLANEOUS No.2832 of 2026
Arising Out of PS. Case No.-222 Year-2025 Thana- SARAI RANJAN District- Samastipur
======================================================
Anjay Kumar @ Manjay Sahni, S/O Maksudan Sahni, R/o Village-
Bhagwatpur Bhuski, P.S.- Sarairanjan, Dist.- Samastipur.
... ... Petitioner/s
Versus
The State of Bihar
... ... Opposite Party/s
======================================================
Appearance :
For the Petitioner/s : Mr.Surya Narayan Roy
For the Opposite Party/s : Mr.Khurshid Anwar
======================================================
CORAM: HONOURABLE MR. JUSTICE SATYAVRAT VERMA
ORAL ORDER
3 09-02-2026 1. Heard learned counsel for the petitioner and
learned APP for the State.
2. The petitioner seeks bail in anticipation of his
arrest in a case registered for the offences punishable under
Section 30(a) of the Indian Penal Code.
3. The learned counsel for the petitioner submits that
petitioner was granted the privilege of anticipatory bail by order
dated 28.01.2026, but while describing the petitioner’s village, it
was recorded in the order dated 28.01.2026 as Bhagwanpur
Bhuski, when in the anticipatory bail application the name of
the village was recorded as Bhagwatpur Bhuski.
4. In view of the submissions made by the learned
counsel appearing on behalf of the petitioner, the name of the
village of the petitioner in the order dated 28.01.2026 shall be
Patna High Court CR. MISC. No.2832 of 2026(3) dt.09-02-2026
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read as Bhagwatpur Bhuski instead of Bhagwanpur Bhuski.
5. The order dated 28.01.2026 is modified to the
extent as indicated above, rest of the order shall remain the
same.
(Satyavrat Verma, J)
vikash/-
U T
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