Patna High Court

Sapana KumariversusThe State of Bihar

Decided: 12 January 2026
Disposal: WITHDRAWN
Bench: NAWNEET KUMAR PANDEY

Holding

The application is dismissed as infructuous because the trial court has already rendered its judgment.

Summary

Sapana Kumari filed an application before the Patna High Court in connection with Sugauli Rail Police Station Case No. 77 of 2023. During the pendency of that application, the trial court completed the trial and delivered its judgment. The petitioner’s counsel argued that the application had become moot because the substantive proceedings were already concluded. The Court examined the status of the application and held that an application cannot be entertained once the trial court’s judgment is pronounced. Consequently, the Court dismissed the application as infructuous.

Issues considered

Whether an application pending before the High Court can be entertained after the trial court has passed its judgment in the underlying case?

Subjects

criminal procedure
application dismissed
infructuous
trial concluded
High Court order

Judgment

                       IN THE HIGH COURT OF JUDICATURE AT PATNA
                               CRIMINAL MISCELLANEOUS No.44409 of 2024
                     Arising Out of PS. Case No.-77 Year-2023 Thana- SUGAULI RAIL P.S. District- West
                                                         Champaran
                  ======================================================
                  Sapana Kumari D/o Sampat Patel R/o Balwanwa, P.S.-Motihari Town
                  ,District-East Champaran

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

                                                         ... ... Opposite Party/s
                  ======================================================
                  Appearance :
                  For the Petitioner/s     :        Mr.Aditya Nath Jha
                  For the Opposite Party/s :        Mr.Anil Prasad Singh
                  ======================================================
                  CORAM: HONOURABLE MR. JUSTICE NAWNEET KUMAR
                  PANDEY
                                        ORAL ORDER

3    12-01-2026                    Heard.

                                 2. Learned counsel for the petitioner submits that

                    during pendency of this application, the trial of the case has

                    been concluded and judgment has been passed by the trial court

                    and hence, this application has become infructuous.

                                 3. Accordingly, the present application filed in

                    connection with Sugauli Rail P.S. Case No. 77 of 2023 stands

                    dismissed being infructuous.



                                         (Nawneet Kumar Pandey, J)
A.K.V.//-

U      T

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