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Patna High Court

Pankaj Sahni @ Pankaj Kumar @ Pankaj SahaniversusThe State of Bihar

Decided
Disposal
DISMISSED

Holding

A second anticipatory bail application without fresh material is not maintainable and is dismissed.

Summary

The petitioner, Pankaj Sahni, filed a second anticipatory bail application after an earlier application was rejected on merit on 07-11-2025. The petitioner’s counsel argued for relief, but the court noted that the present application did not disclose any new facts or circumstances that would warrant reconsideration. The court referred to the Supreme Court’s decision in G.R. Ananda Babu v. State of Tamil Nadu (2021 SCC OnLine SC 176), which holds that a second anticipatory bail petition without fresh material is not maintainable. Consequently, the High Court dismissed the second anticipatory bail application. The order was pronounced by Justice Prabhat Kumar Singh.

Issues considered

  • Whether a second anticipatory bail application can be entertained in the absence of new facts or circumstances.
  • Whether the Supreme Court’s ruling in G.R. Ananda Babu v. State of Tamil Nadu governs the maintainability of the present petition.

Subjects

  • anticipatory bail
  • second application
  • maintainability
  • criminal procedure
  • Supreme Court precedent

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.90907 of 2025
                    Arising Out of PS. Case No.-220 Year-2024 Thana- HATHAURI District- Muzaffarpur
                 ======================================================
                 Pankaj Sahni @ Pankaj Kumar @ Pankaj Sahani S/O Anandi Sahani @
                 Anadin Sahni R/O Vill.- Bara Bharti, P.S- Minapur, District - Muzaffarpur

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner      :        Mr. Manoj Kumar, Advocate
                 For the State           :        Mr. Pramod Kumar Pandey, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE PRABHAT KUMAR SINGH
                                       ORAL ORDER

2   10-02-2026                  Heard Mr. Manoj Kumar, learned counsel for the

                   petitioner and Mr. Pramod Kumar Pandey, learned A.P.P. for the

                   State.

                                2. This is second anticipatory bail application on

                   behalf of the petitioner. Earlier, the prayer for grant of

                   anticipatory bail of the petitioner was rejected on merit vide

                   order dated 07.11.2025 passed in Cr. Misc. No. 65976 of 2025.

                                3. This application does not reveal any new facts and

                   circumstances for reconsideration of prayer for grant of

                   anticipatory bail of the petitioner. 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 Anr. reported in

                   2021 SCC OnLine SC 176, this second anticipatory bail on

                   behalf of the petitioner is not maintainable.
             Patna High Court CR. MISC. No.90907 of 2025(2) dt.10-02-2026
                                                         2/2




                                    4. This application is, accordingly, dismissed.



                                             (Prabhat Kumar Singh, J)
shashank/-

U      T


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