Patna High Court

Bhim MandalversusThe State of Bihar

Decided: 30 January 2026
Disposal: DISMISSED
Bench: SATYAVRAT VERMA

Holding

The court held that the anticipatory bail order cannot be modified merely because the petitioner concealed his criminal antecedent.

Summary

The petitioner, Bhim Mandal, had earlier been granted anticipatory bail. He later applied to modify that bail order, alleging that the order was obtained by concealing his criminal antecedent. The State opposed the modification. The Court, adhering to a consistent view, held that an anticipatory bail order should not be altered merely on the ground of concealment of antecedents. Consequently, the application for modification was dismissed.

Issues considered

Whether an anticipatory bail order can be modified on the ground that the petitioner concealed his criminal antecedent

Subjects

anticipatory bail
modification of bail
concealment of criminal antecedent
high court
bail order

Judgment

                       IN THE HIGH COURT OF JUDICATURE AT PATNA
                               CRIMINAL MISCELLANEOUS No.3918 of 2026
                                               In
                               CRIMINAL MISCELLANEOUS No.53585 of 2025
                      Arising Out of PS. Case No.-551 Year-2023 Thana- Excise P.S. District- Madhepura
                  ======================================================
                  Bhim Mandal S/O Dasrath Mandal R/O Village- Sukhasan Chakala, Ward No.
                  3, P.S- Madhepura, Distt.- Madhepura (Bihar).

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

                                                         ... ... Opposite Party/s
                  ======================================================
                  Appearance :
                  For the Petitioner/s     :        Mr.Ranjay Kumar Singh
                  For the Opposite Party/s :        Mr.Uma Shankar Prasad Singh
                  ======================================================
                  CORAM: HONOURABLE MR. JUSTICE SATYAVRAT VERMA
                                        ORAL ORDER

2    30-01-2026               1.    Heard learned counsel for the petitioner and

                    learned A.P.P. for the State.

                              2.    The Court is taking a consistent view of not

                    modifying the order by which petitioner was granted

                    anticipatory bail, in the event, if the same was obtained by

                    concealing the criminal antecedent of the petitioner.

                              3.    Accordingly, the instant modification application is

                    dismissed.



                                               (Satyavrat Verma, J)
Sumit/-

U         T

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