Patna High Court

BASDEV MANJHIversusTHE STATE OF BIHAR

Decided: 16 February 2026
Disposal: DISMISSED
Bench: SANDEEP KUMAR

Holding

The application for modification of the bail order is not maintainable.

Summary

The petitioner, Basdev Manjhi, had been granted regular bail by the Patna High Court in Criminal Miscellaneous No. 88787 of 2025. He filed an application on 16-02-2026 seeking modification of that bail order, alleging that the deponent in the case was unaware of two criminal antecedents against him. The petitioner’s counsel argued that this lack of knowledge warranted a change in the bail conditions. The Court examined whether the application for modification was maintainable under procedural law. It held that the application was not maintainable and therefore dismissed it, while allowing the petitioner to file a fresh application if appropriate.

Issues considered

What is the maintainability of an application seeking modification of a previously granted bail order?

Subjects

bail
modification of bail
maintainability
criminal procedure
high court

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.7288 of 2026
                                              In
                              CRIMINAL MISCELLANEOUS No.88787 of 2025
                   Arising Out of PS. Case No.-535 Year-2025 Thana- CHAKIA District- East Champaran
                 ======================================================
                 Basdev Manjhi S/O Dhobari Manjhi @ Gobri Manjhi R/O Vill.- Koyla
                 Belwa, P.S.- Chakia, Dist.- East Champaran.
                                                                    ... ... Petitioner/s
                                                     Versus
                 The State Of Bihar
                                                             ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :       Mr.Suraj Kumar Tiwari, Adv
                 For the Opposite Party/s :       Mr.Nagendra Prasad, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE SANDEEP KUMAR
                                       ORAL ORDER

2   16-02-2026                    Heard learned counsel or the petitioner and learned

                   counsel for the State.

                                2. The present application has been filed for

                   modification of the order dated 24.12.2025 passed in Cr.

                   Miscellaneous No. 88787 of 2025 by which the petitioner had

                   been granted regular bail by this Court.

                                3. Learned counsel for the petitioner submits that the

                   deponent of the case had no knowledge about two criminal

                   antecedents of the petitioner.

                                4.    This    application       for    modification        is    not

                   maintainable.

                                5. Accordingly, the present modification application

                   is dismissed with the liberty to file a fresh application.



N.K/-                                         (Sandeep Kumar, J)
U     T

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