Disposed¶18

Sanjeet Sah @ Sanjit Sah v. the State of Bihar

Patna HC3 Apr 2026CR. APP (DB)/365/2012

Case brief

AI extract

What is this about?

Abatement of criminal appeal on death of sole appellant; no application for leave to continue appeal by near relative; Section 394 Code of Criminal Procedure 1973; Section 435 Bharatiya Nagarik Suraksha Sanhita 2023; death certificate; Patna High Court; Kaimur (Bhabua); Adhaura Police Station; PS Case No. 7 of 2007; return of trial court record; Sangam Kumar Sahoo CJ; Harish Kumar J.

What did the court decide?

Criminal Appeal declared abated and disposed of; trial court record directed to be sent back to the concerned court immediately, if not required in any other case. ¶18

Sanjeet Sah @ Sanjit Sah Vs the State of Bihar — Patna HC (2026) — LawSathi Research

What the court decided

AI extract

Outcome

Criminal Appeal declared abated and disposed of; trial court record directed to be sent back to the concerned court immediately, if not required in any other case.

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Issue for consideration

Whether the criminal appeal abates upon the death of the sole appellant where no near relative has filed an application for leave to continue the appeal.

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Court's answer

On the basis of the Letter No. 175 dated 10.02.2026 of the Superintendent of Police, Kaimur (Bhabhua), the Report dated 06.02.2026 of the S.H.O., Adhaura Police Station, and the Death Certificate issued by the Department of Planning and Development, Government of Bihar, the court recorded that the sole appellant, Sanjeet Sah @ Sanjit Sah, is dead.

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Ratio / Principle

Since the sole appellant is dead and no near relative has filed any application for leave to continue the appeal, and in view of Section 394 of the Code of Criminal Procedure, 1973 (corresponding to Section 435 of the Bharatiya Nagarik Suraksha Sanhita, 2023), the Criminal Appeal stands abated and is disposed of.

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Detailed headnote1 paragraphs

Patna High Court, Criminal Appeal (DB) No. 365 of 2012 (arising out of PS Case No. 7 of 2007, P.S. Adhaura, District Kaimur (Bhabua)) — Abatement on death of sole appellant. During pendency, the Superintendent of Police, Kaimur (Bhabhua) (Letter No. 175 dated 10.02.2026), the S.H.O., Adhaura Police Station (Report dated 06.02.2026) and a Death Certificate issued by the Department of Planning and Development, Government of Bihar indicated that the sole appellant, Sanjeet Sah @ Sanjit Sah, was dead. No near relative having filed any application for leave to continue the appeal, the Division Bench (Sangam Kumar Sahoo, CJ and Harish Kumar, J; per the Chief Justice), acting under Section 394 of the Code of Criminal Procedure, 1973, corresponding to Section 435 of the Bharatiya Nagarik Suraksha Sanhita, 2023, held that the Criminal Appeal stood abated and disposed of it accordingly, directing that the trial court record be sent back to the concerned court immediately if not required in any other case.

Sanjeet Sah @ Sanjit Sah v. the State of Bihar

Case brief

What is this about?

What did the court decide?

Sanjeet Sah @ Sanjit Sah v. the State of Bihar

Case brief

What is this about?

What did the court decide?

Why is it important?

What the court decided

Issues for consideration

Statutes considered

Procedural history

Parties & counsel

Coram

Case details

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