Patna High Court

Triloki Nath Rai @ Triloki Ray @ Viloki Nath RaiversusThe State of Bihar

Decided: 17 February 2026
Disposal: DISMISSED
Bench: PRABHAT KUMAR SINGH

Holding

A second anticipatory bail petition is not maintainable where there is no change in circumstances or new ground.

Summary

Triloki Nath Rai filed a second anticipatory bail petition after an earlier petition was rejected in 2019. The petition was filed about seven years later without any change in facts or new grounds. The Court observed that the petitioner had not demonstrated any alteration in circumstances that would justify a fresh bail application. Relying on the Supreme Court’s decision in G.R. Ananda Babu v. State of Tamil Nadu (2021 SCC OnLine SC 176), the Court held that a second anticipatory bail petition is not maintainable in the absence of new material. Consequently, the petition was dismissed.

Issues considered

Whether a second anticipatory bail petition can be entertained when there is no change in circumstances or new grounds.
Whether the Supreme Court precedent in G.R. Ananda Babu v. State of Tamil Nadu bars the maintainability of a second anticipatory bail application.

Subjects

anticipatory bail
second petition
maintainability
Supreme Court precedent
criminal procedure

Judgment

                       IN THE HIGH COURT OF JUDICATURE AT PATNA
                               CRIMINAL MISCELLANEOUS No.79105 of 2025
                       Arising Out of PS. Case No.-122 Year-2012 Thana- KATEYA District- Gopalganj
                  ======================================================
                  Triloki Nath Rai @ Triloki Ray @ Viloki Nath Rai S/o Haribansh Rai @ Ram
                  Prasad Rai R/o Village- Belaw Darauli, P.S.- Darauli, Distt.- Siwan
                                                                                ... ... Petitioner/s
                                                    Versus
                  The State of Bihar
                                                                         ... ... Opposite Party/s
                  ======================================================
                  Appearance :
                  For the Petitioner/s     :       Mr. Kumar Harshvardhan, Advocate
                  For the Opposite Party/s :       Ms. Asha Kumari, A.P.P.
                  ======================================================
                  CORAM: HONOURABLE MR. JUSTICE PRABHAT KUMAR SINGH
                                        ORAL ORDER

5    17-02-2026                    Heard learned counsel for the petitioner and learned
                    A.P.P. for the State.
                                 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 03.09.2019 passed in
                    Cr. Misc. No. 55883 of 2019.
                                 3. Petitioner has renewed his prayer for pre-arrest bail
                    after lapse of about seven years and this application does not
                    reveal any change of circumstances or new ground.
                                 4. In view of the aforesaid observation and 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)
Navya/-
U       T

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