Patna High Court

Arjun RayversusThe State of Bihar

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

Holding

The court held that regular bail could not be granted as there was no change in circumstances since the earlier rejection.

Summary

The petitioner, Arjun Ray, filed a regular bail application after his earlier bail request was rejected on 26 September 2025. The High Court observed that the new application was filed merely five months after the rejection and there was no change in circumstances that would justify granting bail. Consequently, the court rejected the bail application. However, noting that the petitioner had been in custody since 17 March 2025, the court directed the trial court to expedite the trial and conclude it within one year of receiving the order. The order was pronounced by Justice Prabhat Kumar Singh.

Issues considered

Whether the petitioner is entitled to regular bail despite the earlier rejection and absence of any change in circumstances

Subjects

regular bail
bail application
change of circumstances
expedited trial
criminal procedure

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.7778 of 2026
                   Arising Out of PS. Case No.-220 Year-2021 Thana- PHULWARIYA District- Gopalganj
                 ======================================================
                 Arjun Ray S/o Late Hasnath Ray R/o Village- Banshi Batrahan, P.S.-
                 Phulwariya (Sripur o.p), District- Gopalganj

                                                                                 ... ... Petitioner/s
                                                      Versus
           1.    The State of Bihar
           2.    Suman Devi W/o Karim Sah Resident of Village- Banshi Batarahan, P.O.-
                 Mishra Batarahan, P.S.- Phulwariya (Sripur O.P.), District- Gopalganj

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :      Mr. Alok Chandra, Advocate
                 For the Opposite Party/s :      Mrs. Usha Kumari 1, A.P.P.
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE PRABHAT KUMAR SINGH
                                       ORAL ORDER

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

                   learned A.P.P. for the State.

                                2. Lastly, the regular bail application of petitioner was

                   rejected vide order dated 26.09.2025 passed in Cr. Misc. No.

                   37793 of 2025.

                                3. Petitioner has renewed his prayer just after five

                   months of the rejection of earlier order and there is no new or

                   any change of circumstance.

                                4. Considering the aforesaid observation, prayer for

                   regular bail of the petitioner is rejected. However, since

                   petitioner is in custody since 17.03.2025, Trial Court is directed

                   to expedite and conclude the trial, preferably, within a period of
              Patna High Court CR. MISC. No.7778 of 2026(2) dt.16-02-2026
                                                          2/2




                        one year from the date of receipt/production of copy of this

                        order.



                                              (Prabhat Kumar Singh, J)
Navya/-

U         T

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