Patna High Court

Shrimati Devi @ Srimati DeviversusThe State of Bihar

Decided: 16 January 2026
Disposal: BAIL REJECTED
Bench: PRABHAT KUMAR SINGH

Holding

A second anticipatory bail petition filed without any change in circumstances is not maintainable.

Summary

Shrimati Devi filed a second anticipatory bail petition in the Patna High Court after an earlier petition was rejected on 18 June 2025. The petitioner argued for bail despite no new facts or change in circumstances being presented. The court noted that the petition did not disclose any material change that could justify a fresh consideration. Referring to the Supreme Court’s decision in G.R. Ananda Babu v. State of Tamil Nadu (2021 SCC OnLine SC 176), the bench held that a second anticipatory bail application is not maintainable. Consequently, the petition was dismissed.

Issues considered

Whether a second anticipatory bail petition can be entertained in the absence of any change of circumstances
Whether the Supreme Court precedent in G.R. Ananda Babu v. State of Tamil Nadu bars a second anticipatory bail application

Subjects

anticipatory bail
second petition
change of circumstances
Criminal Procedure Code
Supreme Court precedent

Judgment

                       IN THE HIGH COURT OF JUDICATURE AT PATNA
                               CRIMINAL MISCELLANEOUS No.75416 of 2025
                     Arising Out of PS. Case No.-77 Year-2025 Thana- SIWAN MUFFASIL District- Siwan
                  ======================================================
                  Shrimati Devi @ Srimati Devi W/o- Shailendra Pandey Resident of Village -
                  Pithaura, P.S. - Dhanauti, District - Siwan

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

                                                         ... ... Opposite Party/s
                  ======================================================
                  Appearance :
                  For the Petitioner/s     :       Mr. Bijay Prakash Singh, Advocate
                  For the Opposite Party/s :       Mrs. Rina Sinha, APP
                  ======================================================
                  CORAM: HONOURABLE MR. JUSTICE PRABHAT KUMAR SINGH
                                        ORAL ORDER

3    16-01-2026                    Heard learned counsel for the parties.
                                 2. This is second anticipatory bail petition. Earlier, the
                    petition, filed for grant of anticipatory bail on behalf of
                    petitioner, stood rejected, vide order dated 18.06.2025 passed
                    in Cr. Misc. No. 36200 of 2025 .
                                 3 . This application does not reveal any change of
                    circumstances or new ground.
                                  4. 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 Anrs reported in 2021 SCC OnLine SC 176,
                    the second anticipatory bail on behalf of the petitioner is not
                    maintainable. It is, accordingly, dismissed.



                                           (Prabhat Kumar Singh, J)
Koushik/-

U      T

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