Patna High Court

Santosh SahaniversusThe State of Bihar

Decided: 30 January 2026
Disposal: ALLOWED
Bench: RAJIV ROY

Holding

The court modified the anticipatory bail order, imposing a Rs. 1,000 payment condition and extending the surrender period by four weeks.

Summary

The petitioner, Santosh Sahani, filed an application seeking modification of the anticipatory bail order dated 22 September 2025 that had been granted by the Patna High Court. The court considered the petitioner's request to alter the conditions of bail, specifically imposing a monetary condition and adjusting the surrender timeline. After hearing counsel for both parties, the court allowed the modification, directing the petitioner to pay Rs. 1,000 to the Lawyers Association of the Patna High Court. Additionally, the court extended the period within which the petitioner must surrender by four weeks. The order thus modifies the original anticipatory bail with new conditions and an extended surrender period.

Issues considered

Whether the anticipatory bail order can be modified on the grounds raised by the petitioner
Whether imposing a payment of Rs. 1,000 to the Lawyers Association is a valid condition for bail
Whether the surrender period can be extended by four weeks

Subjects

anticipatory bail
modification of bail order
conditions of bail
surrender period
criminal procedure

Judgment

                       IN THE HIGH COURT OF JUDICATURE AT PATNA
                               CRIMINAL MISCELLANEOUS No.3905 of 2026
                                               In
                               CRIMINAL MISCELLANEOUS No.59558 of 2025
                   Arising Out of PS. Case No.-567 Year-2025 Thana- KATIHAR NAGAR District- Katihar
                  ======================================================
                  Santosh Sahani S/O Vishwanath Sahani Resident of Village/ Mohalla-
                  Ranighat Gaushala, P.S. - Sahayak, District- Katihar.
                                                                               ... ... Petitioner/s
                                                     Versus
                  The State of Bihar
                                                                        ... ... Opposite Party/s
                  ======================================================
                  Appearance :
                  For the Petitioner/s     :      Mr. Bimal Kumar, Adv.
                  For the Opposite Party/s :      Mr. Umeshanand Pandit, APP
                  ======================================================
                  CORAM: HONOURABLE MR. JUSTICE RAJIV ROY
                                        ORAL ORDER
2    30-01-2026                      Heard Mr. Bimal Kumar, learned counsel for the

                    petitioner and the State.

                                 2. The present application has been preferred for

                    modification of the order dated 22.09.2025 passed in Cr. Misc. No.

                    59558 of 2025 by which the prayer for anticipatory bail of the

                    petitioner was allowed by this Court.

                                 3. For the reasons assigned in different Paragraphs of the

                    petition, the MJC No. 3905 of 2026 is allowed subject to payment of

                    Rs. 1000/- by way of books to the Lawyers Association, Patna High

                    Court.

                                 4. The period of surrender is further extended by four

                    weeks.



                                                 (Rajiv Roy, J)
Vijay Singh/-

U

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