Patna High Court

Pramila DeviversusThe State of Bihar

Decided: 17 January 2026
Disposal: BAIL REJECTED
Bench: SATYAVRAT VERMA

Holding

The court held that a second anticipatory bail application is not entitled to the privilege of anticipatory bail and therefore rejected the petition.

Summary

Petitioner Pramila Devi feared arrest in a case registered under Section 30(a) of the Bihar Prohibition and Excise Act. She had earlier filed an anticipatory bail application (Cr. Misc. No. 20847/2022) which she later withdrew. She subsequently filed a second anticipatory bail application (Cr. Misc. No. 77472/2025). The court observed that a second anticipatory bail application does not merit the privilege of anticipatory bail and declined to grant it. Consequently, the anticipatory bail petition was rejected.

Issues considered

Whether a second anticipatory bail application can be entertained after the petitioner has withdrawn an earlier application
Whether the privilege of anticipatory bail can be denied in such circumstances

Subjects

anticipatory bail
second application
withdrawal of bail application
Bihar Prohibition and Excise Act
criminal procedure

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.77472 of 2025
                    Arising Out of PS. Case No.-26 Year-2022 Thana- BACHHWARA District- Begusarai
                 ======================================================
                 Pramila Devi W/o Ramadhar Singh R/o vill - Suro, P.s.- Bachwara, Distt.-
                 Begusarai

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :      Mr. Braj Bhusan Poddar
                 For the Opposite Party/s :      Mr. Khurshid Anwar
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE SATYAVRAT VERMA
                                       ORAL ORDER

3   17-01-2026                      1. Heard learned counsel for the petitioner and

                   learned A.P.P. for the State.

                                2. The petitioner apprehends her arrest in connection

                   with Bachhwara P.S. Case No.26/2022, registered for the

                   offence punishable under Section 30(a) of Bihar Prohibition and

                   Excise Act.

                                3. This is the second attempt of the petitioner to seek

                   anticipatory bail when petitioner had earlier moved before this

                   court seeking anticipatory bail by filing Cr. Misc. No.

                   20847/2022 and the petitioner had sought permission to

                   withdraw said criminal miscellaneous application as would

                   manifest from the order dated 27.09.2022 (Annexure-1).

                                4. Since this is the second anticipatory bail

                   application, as such the court is not inclined to extend the
             Patna High Court CR. MISC. No.77472 of 2025(3) dt.17-01-2026
                                                         2/2




                       privilege of anticipatory bail to the petitioner.

                                    5. The anticipatory bail application of the petitioner is

                       rejected.



                                                 (Satyavrat Verma, J)
amit/-

U        T

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