Patna High Court

Arun Kumar @ Arun RaiversusThe State of Bihar

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

Holding

A second anticipatory bail application is not maintainable without the emergence of new facts or circumstances.

Summary

Arun Kumar applied for a second anticipatory bail after his earlier application was withdrawn. The petitioner argued for relief, but the court noted that the present application did not disclose any new facts or circumstances that would justify reconsideration. The court referred to the Supreme Court's decision in G.R. Ananda Babu v. State of Tamil Nadu (2021 SCC OnLine SC 176), which holds that a second anticipatory bail petition is not maintainable without fresh material. Consequently, the Patna High Court dismissed the petition. The order was delivered by Justice Prabhat Kumar Singh.

Issues considered

Whether a second anticipatory bail application is maintainable in the absence of new facts or circumstances
Whether the Supreme Court precedent in G.R. Ananda Babu v. State of Tamil Nadu applies to this case

Subjects

anticipatory bail
maintainability
second application
Supreme Court precedent
criminal procedure

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                               CRIMINAL MISCELLANEOUS No.6340 of 2026
                         Arising Out of PS. Case No.-402 Year-2020 Thana- DIGHA District- Patna
                 ======================================================
                 Arun Kumar @ Arun Rai S/o Late Ram Sagar RO 01 Digha Akhara Gali, PS-
                 Digha, District- Patna


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


                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner      :        Mr. Suraj Narain Yadav, Advocate
                 For the State           :        Mr. Mithlesh Kumar Khare, A.P.P.
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE PRABHAT KUMAR SINGH
                                       ORAL ORDER

2   11-02-2026                  Heard learned counsel for the petitioner and learned

                   A.P.P. for the State.

                                2. This is second anticipatory bail application on

                   behalf of the petitioner. Earlier, the prayer for grant of

                   anticipatory bail to the petitioner was dismissed as withdrawn

                   vide order dated 13.08.2025 passed in Cr. Misc. No. 39756 of

                   2025.

                                3. This application does not reveal any new facts and

                   circumstances for reconsideration of prayer for grant of

                   anticipatory bail to the petitioner. 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 Anr. reported in 2021 SCC

                   OnLine SC 176, this second anticipatory bail on behalf of the
            Patna High Court CR. MISC. No.6340 of 2026(2) dt.11-02-2026
                                                        2/2




                      petitioner is not maintainable.

                                   4. This application is, accordingly, dismissed.



                                            (Prabhat Kumar Singh, J)

Shashank/
Abhishek-

U     T

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