Patna High Court
Manish Rai @ Manish Ray @ Manish KumarversusThe State of Bihar
- Decided
- Disposal
- ALLOWED
- Bench
- R P MISHRA
Holding
The bail order is modified to read the correct address of the petitioner.
Summary
Manish Rai filed an application seeking modification of the bail order dated 09.01.2026 because the address mentioned in the cause title of the regular bail petition was incorrect due to miscommunication. The petitioner’s counsel submitted the correct residential address and requested that the order be amended to reflect it. The court examined whether a clerical error in the cause title could be rectified without affecting the substantive bail order. Finding no prejudice to the State and noting that the error was purely administrative, the court ordered that the address in the bail order be read as the correct one. Consequently, the modification application was allowed, and the bail order was amended accordingly.
Issues considered
- Whether a bail order can be modified solely to correct an erroneous address in the cause title?
Subjects
- bail
- modification
- cause title correction
- criminal procedure
- clerical error
Judgment
IN THE HIGH COURT OF JUDICATURE AT PATNA
CRIMINAL MISCELLANEOUS No.9243 of 2026
In
CRIMINAL MISCELLANEOUS No.87640 of 2025
Arising Out of PS. Case No.-773 Year-2023 Thana- BIDUPUR District- Vaishali
======================================================
Manish Rai @ Manish Ray @ Manish Kumar S/O Satendra Ray @ Satender
Ray @ Satender Raye R/O Village- Naya Tola Majlispur, P.S- Bidupur, Distt.-
Vaishali.
... ... Petitioner/s
Versus
The State of Bihar
... ... Opposite Party/s
======================================================
Appearance :
For the Petitioner/s : Mr.Ravish Mishra, Advocate
For the Opposite Party/s : Mr.Ajay Kumar Jha, APP
======================================================
CORAM: HONOURABLE MR. JUSTICE RUDRA PRAKASH
MISHRA
ORAL ORDER
2 06-02-2026 Heard learned counsel for the petitioner and learned
counsel for the State.
2. The present application has been filed for
modification of the order dated 09.01.2026 passed in Cr. Misc.
No. 87640 of 2025 by which the petitioner was granted bail in
connection with Bidupur P.S. case No. 773 of 2023 to the
satisfaction of Court below.
3. Learned counsel for the petitioner, referring to
statement made in paragraph Nos. 3 and 4 of the application,
submits that due to miscommunication, the correct residing
address of the petitioner was not stated in the cause title of the
regular bail petition and as such the same got typed in the order
Patna High Court CR. MISC. No.9243 of 2026(2) dt.06-02-2026
2/2
dated 09.01.2026. Learned counsel for the petitioner submits
that the correct address of the petitioner is: ‘Manish Rai @
Manish Ray @ Manish Kumar, aged about 25 years, Gender
(Male), S/O- Satendra Ray @ Satender Ray @ Satender Raye.
R/O- village Sukumarpur, Jafrabad Tok, Arazi Beshinao Barar,
Jafrabad, P.S.- Raghopur (Rustampur O.P.), District- Vaishali
and the same is also the address of his parents.
4. Considering the above, let in the cause title of the order
dated 09.01.2026 passed in Cr. Misc. No. 87640 of 2025, the
address of the petitioner be read as ‘Manish Rai @ Manish Ray
@ Manish Kumar, aged about 25 years, Gender (Male), S/O-
Satendra Ray @ Satender Ray @ Satender Raye. R/O- village
Sukumarpur, Jafrabad Tok, Arazi Beshinao Barar, Jafrabad,
P.S.- Raghopur (Rustampur O.P.), District- Vaishali”.
5. The order dated 09.01.2026 passed in Cr. Misc. No.
87640 of 2025 is modified only to the extent as indicated above.
6. The modification application is, accordingly,
allowed.
(Rudra Prakash Mishra, J)
Pankaj/-
U T
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