Patna High Court

Manisha DeviversusPankaj Kumar Jha @ Lal Jha

Decided: 18 February 2026
Disposal: DISMISSED
Bench: BIBEK CHAUDHURI

Holding

Section 403 of the BNSS bars alteration of a final judgment, so the application for modification is dismissed.

Summary

Manisha Devi and Anuja filed an application seeking modification of a final judgment dated 28 July 2025 against Pankaj Kumar Jha and the State of Bihar. The court examined whether, under Section 403 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), a final judgment can be altered. It held that the specific provision expressly prohibits any alteration of a final order. Consequently, the court found no merit in the petition for modification. The application was therefore rejected.

Issues considered

Whether Section 403 of the BNSS permits alteration of a final judgment
Whether the application for modification of the order dated 28 July 2025 is maintainable

Legislation cited

Bharatiya Nagarik Suraksha Sanhita — s. 403

Subjects

modification of judgment
final judgment
BNSS
Section 403
criminal revision
appellate jurisdiction

Judgment

                       IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.74665 of 2025
                                                       In
                                   CRIMINAL REVISION No.932 of 2024
                  ======================================================
             1.    Manisha Devi W/o- Pankaj Kumar Jha @ Lal Jha, D/O Late Ganesh
                   Chandra Jha R/O Village- Chikna, Ps- Ghoghardiha, Dist- Madhubani.
                   Presently R/O Village- Bhakharain, Ps- Madhepur, Dist- Madhubani
             2.   Anuja D/o- Pankaj Kumar Jha @ Lal Jha R/O Village- Bhakharain, PS-
                  Madhepur, Distt- Madhubani, through her mother Manisha Devi
                                                                         ... ... Petitioner/s
                                                   Versus
             1.   Pankaj Kumar Jha @ Lal Jha S/O Late Gopal Jha R/O Vill.- Chikna, P.S.-
                  Ghoghardiha, Dist.- Madhubani
             2.   The State of Bihar
                                                         ... ... Opposite Party/s
                  ======================================================
                  Appearance :
                  For the Petitioner/s     :      Mr. Pramod Kr. Mishra, Advocate
                  For the Opposite Party/s :      Mr. Sanjeev Kumar Jha, Advocate
                  For the State            :      Dr. Mrityunjaya Kr. Gautam, Advocate
                  ======================================================
                  CORAM: HONOURABLE MR. JUSTICE BIBEK CHAUDHURI
                                        ORAL ORDER

2    18-02-2026                    Heard the parties.

                                   2. In view of the specific provision laid down in

                    Section 403 of Bharatiya Nagarik Suraksha Sanhita (BNSS), the

                    Court cannot alter its final judgment.

                                 3. Therefore, I do not find any merit in the instant

                    application for modification of the order dated 28th July, 2025.

                                 4. Accordingly, the instant application is rejected.



                                               (Bibek Chaudhuri, J)
Jyoti Kumari/-

U

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