Patna High Court

Ramayan RayversusThe State of Bihar

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

Holding

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

Summary

The petitioner, Ramayan Ray, filed a second anticipatory bail petition after an earlier petition was withdrawn. The court noted that there was no change in circumstances or any new ground to justify a fresh application. Citing 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 presented.

Issues considered

Whether a second anticipatory bail petition can be entertained in the absence of a change in circumstances
Whether the Supreme Court precedent in G.R. Ananda Babu v. State of Tamil Nadu bars a second anticipatory bail application

Subjects

anticipatory bail
second petition
change of circumstances
criminal procedure
Supreme Court precedent

Judgment

                       IN THE HIGH COURT OF JUDICATURE AT PATNA
                               CRIMINAL MISCELLANEOUS No.3092 of 2026
                         Arising Out of PS. Case No.-739 Year-2024 Thana- GARKHA District- Saran
                  ======================================================
                  Ramayan Ray Son of Late Ginni Ray R/o Vill. - Narayanpur, P.S. - Garkha,
                  District - Saran, Bihar.

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

                                                         ... ... Opposite Party/s
                  ======================================================
                  Appearance :
                  For the Petitioner/s     :       Mr. Danish Raja, Advocate
                  For the Opposite Party/s :       Mr. Ram Naresh Ray, 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
                    06.05.2025 passed in Cr. Misc. No. 26971 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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