Allowed¶20

Manish Kumar v. The State of Bihar

Patna HC3 Apr 2026CR. MISC./21778/2026

Case brief

AI extract

What is this about?

Patna High Court; Criminal Miscellaneous No. 21778 of 2026 in Criminal Miscellaneous No. 1211 of 2026; Manish Kumar v. The State of Bihar; modification of bail order dated 15.01.2026; release on bail without awaiting framing of charge; sanction report not furnished by prosecution; cognizance taken 02.02.2026; parity with released co-accused; Danapur PS Case No. 981 of 2025; Justice S. B. Pd. Singh; decided 03-04-2026; no statute or precedent cited.

What did the court decide?

Application for modification allowed: the condition requiring release after framing of charge is deleted; petitioner to be released in accordance with law without awaiting framing of charge, subject to all other conditions of the order dated 15.01.2026. ¶20

Manish Kumar Vs The State of Bihar — Patna HC (2026) — LawSathi Research

What the court decided

AI extract

Outcome

¶20

Issue for consideration

Whether the condition in the order dated 15.01.2026 in Cr. Misc. No. 1211 of 2026 directing that the petitioner be released on bail only after framing of charge should be modified so as to permit his release without awaiting framing of charge.

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Ratio / Principle

Upon consideration of the submissions and perusal of the record, the Court found it appropriate to modify the order dated 15.01.2026 passed in Cr. Misc. No. 1211 of 2026.

¶18

Key takeaways

The condition in the order dated 15.01.2026 that the petitioner be released after framing of charge is hereby modified; the petitioner is directed to be released in accordance with law without awaiting framing of charge, subject to fulfilment of all other conditions contained in that order.ratio¶19
The order dated 15.01.2026 stands modified only to the aforesaid extent; no other part of that order is disturbed.ratio¶20

Detailed headnote1 paragraphs

Bail condition — modification. Patna High Court (S. B. Pd. Singh, J.), by order dated 03-04-2026 in Cr. Misc. No. 21778 of 2026 (in Cr. Misc. No. 1211 of 2026, arising out of Danapur PS Case No. 981 of 2025), modified its order dated 15.01.2026 whereby petitioner Manish Kumar had been granted bail on the condition that he be released only after framing of charge. Counsel for the petitioner pointed out that despite cognizance taken on 02.02.2026, no charge had been framed owing to non-supply of the sanction report, charge-framing was not imminent, and co-accused on a similar footing had already been released. On consideration of the submissions and the record, the Court modified the condition and directed release in accordance with law without awaiting framing of charge, leaving all other conditions of the bail order intact.

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IN THE HIGH COURT OF JUDICATURE AT PATNA CRIMINAL MISCELLANEOUS No.21778 of 2026 In

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CRIMINAL MISCELLANEOUS No.1211 of 2026

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Arising Out of PS. Case No.-981 Year-2025 Thana- DANAPUR District- Patna

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

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Manish Kumar Son of Ramnirekhan Rai @ Ramrekhan Rai Resident of Village - Naya Tola Saguna Ward No.- 15, P.S.- Danapur, District - Patna.

... ... Petitioner/s

Versus

The State of Bihar

... ... Opposite Party/s

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

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For the Petitioner/s : Mrs. Jyotsna Rani Mishra For the Opposite Party/s : Mr. Madan Kumar, APP ======================================================

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CORAM: HONOURABLE MR. JUSTICE S. B. PD. SINGH ORAL ORDER

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2 03-04-2026

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The present application has been filed on behalf of the petitioner for modification of the order dated 15.01.2026 passed in Cr. Misc. No. 1211 of 2026 by which the petitioner has been granted bail and directed to be released on bail after framing of charge.

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Learned counsel for the petitioner submits that due to latches in part of prosecution, no sanction report was made available on account thereof no charge has been framed till date. Cognizance has been taken on 02.02.2026 but there is no chance of framing of charge in near future. She further submits that other co-accused persons, whose cases stand on a similar footing, have already been granted bail and have accordingly been released.

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Having considered the submissions and upon

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Patna High Court CR. MISC. No.21778 of 2026(2) dt.03-04-2026 2/2

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perusal of the record, this Court finds it appropriate to modify the aforesaid order.

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Accordingly, the condition stipulated in order dated 15.01.2026 to the effect that the petitioner shall be released after framing of charge is hereby modified, and it is directed that the petitioner shall be released in accordance with law, without awaiting framing of charge, subject to fulfillment of all other conditions as contained in the said order.

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Order dated 15.01.2026 stands modified to the aforesaid extent only.

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(S. B. Pd. Singh, J)

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Ankit Kumar/-

Manish Kumar v. The State of Bihar

Case brief

What is this about?

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Manish Kumar v. The State of Bihar

Case brief

What is this about?

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What the court decided

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