Patna High Court

Pravesh Kumar Mandal @ Pravesh KumarversusThe State of Bihar

Decided: 5 February 2026
Disposal: DISMISSED
Bench: PRABHAT KUMAR SINGH

Holding

A second anticipatory bail petition is not maintainable without a change of circumstances, and therefore must be dismissed.

Summary

The petitioner, Pravesh Kumar Mandal, filed a second anticipatory bail petition after an earlier petition was rejected on 24 June 2025. The petition asserted no change in circumstances or new grounds to merit relief. The Court noted that, per the Supreme Court's decision in G.R. Ananda Babu v. State of Tamil Nadu (2021 SCC OnLine SC 176), a second anticipatory bail application is not maintainable. Consequently, the petition was dismissed for lack of merit. No statutory provisions were specifically cited.

Issues considered

Whether a second anticipatory bail petition is maintainable in the absence of a change of circumstances
Whether the Supreme Court precedent on second anticipatory bail applies to the present case

Subjects

anticipatory bail
second petition
change of circumstances
Supreme Court precedent

Judgment

                       IN THE HIGH COURT OF JUDICATURE AT PATNA
                               CRIMINAL MISCELLANEOUS No.75790 of 2025
                       Arising Out of PS. Case No.-10 Year-2025 Thana- LADANIA District- Madhubani
                  ======================================================
                  Pravesh Kumar Mandal @ Pravesh Kumar S/O Ram Prakash Mandal
                  Resident of Village- Lacchminia, P.S- Ladaniya, District- Madhubani.

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

                                                         ... ... Opposite Party/s
                  ======================================================
                  Appearance :
                  For the Petitioner/s     :       Mr. Brisketu Sharan Pandey, Advocate
                  For the Opposite Party/s :       Mr. Chandra Bhushan Prasad , APP
                  ======================================================
                  CORAM: HONOURABLE MR. JUSTICE PRABHAT KUMAR SINGH
                                        ORAL ORDER

2    05-02-2026                    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 24.06.2025 passed
                    in Cr. Misc. No. 20713 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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