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Umesh Singh Vs The State of Bihar — Patna HC (2025) — LawSathi Research

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Patna HC
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Umesh Singh Vs The State of BiharUmesh Singh v. The State of Bihar

Dismissed¶23

Umesh Singh v. The State of Bihar

Anticipatory bail condition – exemption from personal appearance

Patna HC13 Aug 2025CR. MISC./37432/2025

Case brief

AI extract

What is this about?

Patna High Court, Cr. Misc. No. 37432 of 2025, decided 13-08-2025 by Chandra Prakash Singh, J. Modification application seeking exemption from personal appearance imposed as a condition of anticipatory bail (order dated 08.11.2023 in Cr. Misc. No. 48247/2023, Complaint Case No. 322/2021, PS Case No. 322/2021, Samastipur) rejected; medical grounds (leg fracture accident 18.06.2024, bed-rest advice 06.12.2024) doubted as documents alleged false and treatment by Spine Surgeon而非Orthopedist questioned by A.P.P.; application dismissed.

What did the court decide?

The Court found substance in the contention of learned counsel for the State, i.e., that the medical documents produced by the petitioner appear false and that treatment by a Spine Surgeon (rather than an Orthopedist) for leg fractures creates doubt. ¶23

What the court decided

AI extract

Outcome

Dismissed

Issue for consideration

Whether the petitioner, who was granted anticipatory bail on 08.11.2023 in Cr. Misc. No. 48247/2023 subject to a condition of personal appearance before the Court below on every date, should be exempted from personally appearing before the learned court of Judicial Magistrate First Class in connection with Complaint Case No. 322/2021 on account of his medical condition.

Court's answer

The Court found substance in the contention of learned counsel for the State, i.e., that the medical documents produced by the petitioner appear false and that treatment by a Spine Surgeon (rather than an Orthopedist) for leg fractures creates doubt.

Ratio / Principle

The Court was not inclined to allow the modification application seeking exemption from personal appearance and rejected it.

Detailed headnote1 paragraphs

Anticipatory bail condition - exemption from personal appearance - Petitioner, granted anticipatory bail on 08.11.2023 in Cr. Misc. No. 48247/2023 (Complaint Case No. 322/2021, Samastipur) on condition of physical presence before the Court below on every date, sought modification/exemption on medical grounds (accident on 18.06.2024 causing leg fractures; bed-rest advised per Annexure-P5 dated 06.12.2024 for eight months). State (A.P.P.) contended the medical documents appear false and that treatment by a Spine Surgeon instead of an Orthopedist for leg fractures creates doubt. Court found substance in the State's contention and rejected the modification application.

A

IN THE HIGH COURT OF JUDICATURE AT PATNA CRIMINAL MISCELLANEOUS No.37432 of 2025

In

CRIMINAL MISCELLANEOUS No.48247 of 2023

Arising Out of PS. Case No.-322 Year-2021 Thana- SAMASTIPUR COMPLAINT CASE District- Samastipur

======================================================

Umesh Singh Son Of Bishambhar Singh Vill -mahisi Ward No 5 Ps -bibhutipur District- Samastipur Bihar

... ... Petitioner/s

Versus

The State of Bihar

... ... Opposite Party/s

====================================================== Appearance :

For the Petitioner/s : Mr.Shashank Shekhar Kunwar For the Opposite Party/s : Mr.Madhuri Lata ======================================================

CORAM: HONOURABLE MR. JUSTICE CHANDRA PRAKASH SINGH

ORAL ORDER

2 13-08-2025

Heard learned counsel for the petitioner and learned

APP for the State.

The present application has been filed for modification of the order dated 08.11.2023 passed in Cr. Misc. No. 48247/2023.

Learned counsel for the petitioner has submitted that the petitioner was granted anticipatory bail vide order dated 08.11.2023 passed in Cr. Misc. No. 48247/2023 in connection with Complaint Case No. 322/2021 in which the petitioner was directed to remain physically present before the learned Court below on each and every date, failing which on two consecutive dates without reasonable cause, the bail bond of the petitioner is liable to be cancelled but unfortunately on 18.06.2024, the

Patna High Court CR. MISC. No.37432 of 2025(2) dt.13-08-2025 2/2

petitioner met with an accident in which his legs got fractured. As per Annexure-P5, 06.12.2024, the petitioner was advised for a complete bed-rest for a period of eight months. Thereafter, the condition of the petitioner became worse that he requires the help of four persons to move in the house. So, the petitioner seeks exemption from personally appearing before the learned court of Judicial Magistrate First Class in connection with Complaint Case No. 322/2021.

Learned A.P.P. for the State has submitted that the documents produced on behalf of the petitioner appears to be false. It is further submitted that the petitioner has fracture injury on his legs so he should be treated by an Orthopedist but as per Annexure 4 and 5 the petitioner's treatment is being done by a Spine Surgeon which creates doubt.

Considering the aforesaid facts and circumstances of the case as well as the finding substance in the contention of learned counsel for the State, this Court is not inclined to allow the present modification application filed by learned counsel for the petitioner and the same is rejected.

(Chandra Prakash Singh, J)

atul/-

U T

Issues for consideration

1 issue framed by the court

AI extract

1.
Whether the petitioner, who was granted anticipatory bail on 08.11.2023 in Cr. Misc. No. 48247/2023 subject to a condition of personal appearance before the Court below on every date, should be exempted from personally appearing before the learned court of Judicial Magistrate First Class in connection with Complaint Case No. 322/2021 on account of his medical condition.¶21
The court held
The Court found substance in the contention of learned counsel for the State, i.e., that the medical documents produced by the petitioner appear false and that treatment by a Spine Surgeon (rather than an Orthopedist) for leg fractures creates doubt.ratio¶23

Procedural history

How this case reached the court

AI extract

Order under challenge
Order dated 08.11.2023 passed in Cr. Misc. No. 48247/2023 granting anticipatory bail subject to a condition that the petitioner remain physically present before the learned Court below on each and every date; the present application sought modification of that order.¶18
08.11.2023
Prior proceeding
Matter arises out of PS Case No. 322 of 2021, Samastipur Complaint Case, District Samastipur.¶4
Prior proceeding
Petitioner was granted anticipatory bail vide order dated 08.11.2023 in Cr. Misc. No. 48247/2023 in connection with Complaint Case No. 322/2021, with a direction to remain physically present before the learned Court below on each and every date, failing which on two consecutive dates without reasonable cause the bail bond would be liable to be cancelled.¶19
Prior proceeding
On 18.06.2024 the petitioner met with an accident in which his legs got fractured.¶21
Prior proceeding
As per Annexure-P5 dated 06.12.2024, the petitioner was advised complete bed-rest for eight months; his condition subsequently worsened such that he requires the help of four persons to move in the house.¶21

Parties & counsel

AI extract

petitioner
Umesh Singh Son Of Bishambhar Singh Vill -mahisi Ward No 5 Ps -bibhutipur District- Samastipur Bihar¶6
Shashank Shekhar Kunwar
respondent
The State of Bihar¶9
Madhuri Lata

Coram

AI extract

Chandra Prakash Singhauthor¶13

Case details

As recorded by the court registry

Court: Patna HC
Decided on: 13 Aug 2025 · August
Registered: 31 May 2025
Case no.: CR. MISC./37432/2025
CNR: BRHC010448592025
Bench: Chandra Prakash Singh
Disposal: BAIL REJECTED
Case type: CRIMINAL MISCELLANEOUS

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Cite this judgement

Umesh Singh v. The State of Bihar, CR. MISC./37432/2025 (PAT), decided on 13 August 2025.

The Patna High Court publishes no neutral citation for this judgement — cite it by case number and date of decision.

Procedural history5

Order dated 08.11.2023 passed in Cr. Misc. No. 48247/2023 granting anticipatory bail subject to a condition that the petitioner remain physically present before the learned Court below on each and every date; the present application sought modification of that order.08.11.2023
Matter arises out of PS Case No. 322 of 2021, Samastipur Complaint Case, District Samastipur.
Petitioner was granted anticipatory bail vide order dated 08.11.2023 in Cr. Misc. No. 48247/2023 in connection with Complaint Case No. 322/2021, with a direction to remain physically present before the learned Court below on each and every date, failing which on two consecutive dates without reasonable cause the bail bond would be liable to be cancelled.

View full history

Bench / Coram

Chandra Prakash Singh

Parties & counsel