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Naresh Sah Vs The State of Bihar — Patna HC (2026) — LawSathi Research

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Patna HC
2026
Naresh Sah Vs The State of BiharNaresh Sah v. The State of Bihar

Allowed¶22

Naresh Sah v. The State of Bihar

Anticipatory bail – modification of order

Patna HC19 Jun 2026CR. MISC./36793/2026

Case brief

AI extract

What is this about?

Patna High Court, Harish Kumar, J., decided 19-06-2026; Cr. Misc. No. 36793 of 2026 arising out of Cr. Misc. No. 57171 of 2025 and PS Case No.-115 Year-2025, Thana-Phenhara, District-East Champaran; modification of anticipatory bail order dated 27.08.2025 to correct father's name of petitioners Naresh Sah and Rajesh Sah @ Rajesh from 'Late Kapal Sah' to 'Late Kapal Sah @ Late Kapildev Sah'; Aadhaar Cards Annexure-P/2 series; State (APP Mr. Nand Kishore Prasad) raised no objection; four weeks further time to surrender and furnish bail bond; order stands modified accordingly.

What did the court decide?

Modification of the order dated 27.08.2025: the father's name of the petitioners to be read as 'Late Kapal Sah @ Late Kapildev Sah' in place of 'Late Kapal Sah' in the cause title, with four weeks further time to surrender and furnish bail bond.

Why is it important?

The name of the petitioners' father is to be read as 'Late Kapal Sah @ Late Kapildev Sah' in place of 'Late Kapal Sah' in the cause title of the order dated 27.08.2025 passed in Cr. Misc. No. 57171. ¶20

What the court decided

AI extract

Outcome

Modification of the order dated 27.08.2025: the father's name of the petitioners to be read as 'Late Kapal Sah @ Late Kapildev Sah' in place of 'Late Kapal Sah' in the cause title, with four weeks further time to surrender and furnish bail bond.

Issue for consideration

Whether the father's name of the petitioners in the cause title of the order dated 27.08.2025 passed in Cr. Misc. No. 57171 of 2025 should be corrected from 'Late Kapal Sah' to 'Late Kapal Sah @ Late Kapildev Sah'.

Court's answer

The name of the petitioners' father is to be read as 'Late Kapal Sah @ Late Kapildev Sah' in place of 'Late Kapal Sah' in the cause title of the order dated 27.08.2025 passed in Cr. Misc. No. 57171.

Ratio / Principle

Four weeks further time is allowed to the petitioners to surrender and furnish bail bond.

Key takeaways

The order dated 27.08.2025 stands modified accordingly.ratio¶22

Detailed headnote1 paragraphs

Anticipatory bail — modification of order — correction of name in cause title. By order dated 27.08.2025 in Cr. Misc. No. 57171 of 2025, the Patna High Court had granted anticipatory bail to Naresh Sah and Rajesh Sah @ Rajesh along with others, but owing to inadvertence carried over from the FIR, the father's name in the cause title was recorded as 'Late Kapal Sah' instead of 'Late Kapal Sah @ Late Kapildev Sah'. On a modification application (Cr. Misc. No. 36793 of 2026) supported by the petitioners' Aadhaar Cards placed on record as Annexure-P/2 series, and with no objection from the State, Harish Kumar, J., directed that the father's name of the petitioners be read as 'Late Kapal Sah @ Late Kapildev Sah' in place of 'Late Kapal Sah' in the cause title of the order dated 27.08.2025, allowed four weeks further time to the petitioners to surrender and furnish bail bond, and ordered that the order dated 27.08.2025 stand modified accordingly.

A

IN THE HIGH COURT OF JUDICATURE AT PATNA CRIMINAL MISCELLANEOUS No.36793 of 2026

In

CRIMINAL MISCELLANEOUS No.57171 of 2025

Arising Out of PS. Case No.-115 Year-2025 Thana- PHENHARA District- East Champaran

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

Naresh Sah Son of Late Kapal Sah @ Late Kapildev Sah Resident of Village -Mankarwa, Police Station- Phenhara,District - East Champaran at Motihari

Rajesh Sah @ Rajesh Son of Late Kapal Sah @ Late Kapildev Sah Resident of Village Mankarwa, Police Station- Phenhara,District - East Champaran at Motihari

... ... Petitioner/s

Versus

The State of Bihar

... ... Opposite Party/s

====================================================== Appearance : For the Petitioner/s : Ms. Milli Kumari, Adv. For the Opposite Party/s : Mr. Nand Kishore Prasad, APP ======================================================

CORAM: HONOURABLE MR. JUSTICE HARISH KUMAR ORAL ORDER

2 19-06-2026 Heard Ms. Milli Kumari, learned Advocate for the petitioners and the APP for the State.

The present application is filed seeking modification of the order dated 27.08.2025 passed by this Court in Cr. Misc. No. 57171 of 2025, whereby the petitioners along with others have been allowed the privilege of anticipatory bail.

Learned Advocate for the petitioners submitted that because of inadvertence in the cause title of the bail application, the father’s name of the petitioners, namely, Naresh Sah and Rajesh Sah @ Rajesh has been wrongly mentioned as Late Kapal Sah in place of Late Kapal Sah @ Late Kapildev Sah . It is submitted that

Patna High Court CR. MISC. No.36793 of 2026(2) dt.19-06-2026 2/2

since in the FIR the name of the father has been wrongly mentioned, due to that, in the petition similar mistake has occurred. To support the aforesaid contention with regard to name of the petitioners father as Late Kapildev Sah, the copies of the Aadhaar Card of the petitioners have also been placed on record as Annexure-P/2 series.

Learned Advocate for the State has no objection with respect to the correction of the father’s name of the petitioners.

Having considered the submissions advanced, let the name of the father’s of the petitioners be read as Late Kapal Sah @ Late Kapildev Sah in place of Late Kapal Sah in the cause title of the order dated 27.08.2025 passed in Cr. Misc. No. 57171.

Four weeks further time is allowed to the petitioners to surrender and furnish bail bond.

The order dated 27.08.2025 stands modified accordingly.

(Harish Kumar, J)

shivank/-

U T

Issues for consideration

1 issue framed by the court

AI extract

1.
Whether the father's name of the petitioners in the cause title of the order dated 27.08.2025 passed in Cr. Misc. No. 57171 of 2025 should be corrected from 'Late Kapal Sah' to 'Late Kapal Sah @ Late Kapildev Sah'.¶16
The court held
The name of the petitioners' father is to be read as 'Late Kapal Sah @ Late Kapildev Sah' in place of 'Late Kapal Sah' in the cause title of the order dated 27.08.2025 passed in Cr. Misc. No. 57171.ratio¶20

Procedural history

How this case reached the court

AI extract

Order under challenge
Order dated 27.08.2025 passed by this Court in Cr. Misc. No. 57171 of 2025 granting anticipatory bail to the petitioners along with others; the father's name in its cause title was recorded as 'Late Kapal Sah' and was sought to be modified.¶15
Patna High Court · 27.08.2025
Prior proceeding
The matter arises out of PS Case No.-115 Year-2025, Thana-Phenhara, District-East Champaran.¶4
Prior proceeding
By the order dated 27.08.2025 in Cr. Misc. No. 57171 of 2025, the petitioners along with others had been allowed anticipatory bail.¶15

Parties & counsel

AI extract

petitioner
Naresh Sah¶6
Ms. Milli Kumari
petitioner
Rajesh Sah @ Rajesh¶7
Ms. Milli Kumari
respondent
The State of Bihar¶10
Mr. Nand Kishore Prasad

Coram

AI extract

Harish Kumarauthor¶13

Case details

As recorded by the court registry

Court: Patna HC
Decided on: 19 Jun 2026 · June
Registered: 20 May 2026
Case no.: CR. MISC./36793/2026
CNR: BRHC010475382026
Bench: Harish Kumar
Disposal: ALLOWED
Case type: Criminal Miscellaneous

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Cite this judgement

Naresh Sah v. The State of Bihar, CR. MISC./36793/2026 (PAT), decided on 19 June 2026.

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

Procedural history3

Order dated 27.08.2025 passed by this Court in Cr. Misc. No. 57171 of 2025 granting anticipatory bail to the petitioners along with others; the father's name in its cause title was recorded as 'Late Kapal Sah' and was sought to be modified.Patna High Court · 27.08.2025
The matter arises out of PS Case No.-115 Year-2025, Thana-Phenhara, District-East Champaran.
By the order dated 27.08.2025 in Cr. Misc. No. 57171 of 2025, the petitioners along with others had been allowed anticipatory bail.

View full history

Bench / Coram

Harish Kumar

Parties & counsel