Patna High Court
Ranjan KumarversusThe State Of Bihar
- Decided
- Disposal
- DISPOSED
- Bench
- SATYAVRAT VERMA
Holding
The court modified the anticipatory bail order to correctly state that the petitioner has four prior cases under the Excise Act and conditioned confirmation of the bail on verification of that antecedent.
Summary
The petitioner, Ranjan Kumar, was granted anticipatory bail on 23‑02‑2026. The bail order erroneously recorded that he had two prior cases, whereas a supplementary affidavit showed he actually had four cases under the Excise Act involving the alleged recovery of 4.520 litres of liquor. The petitioner’s counsel sought correction of this factual mistake. The High Court examined the supplementary affidavit and modified paragraph 6 to reflect the correct antecedent of four cases, and altered paragraph 10 to condition confirmation of the provisional bail on verification of the number of prior cases. If verification shows more than four cases, the bail will not be confirmed; if exactly four, the provisional bail is confirmed. The remainder of the order was left unchanged.
Issues considered
- Whether the anticipatory bail order can be amended to correct the factual record of the petitioner’s criminal antecedent
- Whether a condition of verification of antecedent can be imposed on the confirmation of provisional anticipatory bail
Legislation cited
Subjects
- anticipatory bail
- criminal antecedent
- order modification
- Excise Act
- provisional bail
- verification condition
Judgment
IN THE HIGH COURT OF JUDICATURE AT PATNA
CRIMINAL MISCELLANEOUS No.91613 of 2025
Arising Out of PS. Case No.-178 Year-2025 Thana- ARERAJ District- East Champaran
======================================================
Ranjan Kumar S/O Dhanesh Chaudhary R/O Village- Sukul Tola ward no. 8,
P.S.- Areraj, Dist.- East Champaran.
... ... Petitioner/s
Versus
The State Of Bihar
... ... Opposite Party/s
======================================================
Appearance :
For the Petitioner/s : Mr. Vikash Kumar Pankaj, Advocate
For the Opposite Party/s : Mr. Pradeep Narain Kumar, APP
======================================================
CORAM: HONOURABLE MR. JUSTICE SATYAVRAT VERMA
ORAL ORDER
4 26-02-2026 1. Heard learned counsel for the petitioner and the
learned APP for the State.
2. The learned counsel for the petitioner submits that
petitioner was granted the privilege of anticipatory bail by an
order dated 23.02.2026. It is next submitted that at Para-6 of the
order dated 23.02.2026, it was recorded that petitioner has
antecedent of two cases, but then petitioner has antecedent of
four cases and the additional two cases were brought by way of
supplementary affidavit, but inadvertently, at Para-6 it was
recorded that petitioner has antecedent of two cases when he has
antecedent of four cases.
3. The Court has perused the supplementary affidavit.
4. After hearing the learned counsel for the parties,
Para-6 is modified to the extent that it shall be read- Learned
Patna High Court CR. MISC. No.91613 of 2025(4) dt.26-02-2026
2/2
counsel for the petitioner submits that petitioner has antecedent
of four cases under the excise act and allegation is of recovery
of 4.520 liters of liquor from a place adjacent to the house of the
petitioner and accordingly, Para 10 is also modified to the extent
that it shall be read- It is made clear that thereafter the learned
Trial Court shall verify the criminal antecedent of the petitioner
and in the event if it is found that petitioner has antecedent of more
than four cases then it would be presumed that petitioner, for the
purposes of seeking anticipatory bail, had concealed his antecedent
before this Court, as such, the provisional anticipatory bail order
shall not be confirmed, but after verification if it is found that
petitioner has antecedent of four cases only, in that event the
provisional anticipatory bail order shall be confirmed forthwith.
5. The order dated 23.02.2026 is modified to the extent
indicated above.
6. Rest of the order shall remain intact.
(Satyavrat Verma, J)
Rishabh/-
U T
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