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Md. Firoj @ Firoj Vs The State of Bihar — Patna HC (2026) — LawSathi Research

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Patna HC
2026
Md. Firoj @ Firoj Vs The State of BiharMd. Firoj @ Firoj v. The State of Bihar

Allowed¶17

Md. Firoj @ Firoj v. The State of Bihar

Anticipatory bail – modification of bail condition

Patna HC9 Jan 2026CR. MISC./68761/2025

Case brief

AI extract

What is this about?

Single-judge Patna High Court order allowing a modification application against an anticipatory-bail condition requiring the petitioner's father to stand bailor; mother Madina Khatoon substituted after production of a death certificate (Annexure-P/3) showing the father died on 05.06.2023; petitioner permitted to surrender till 30.01.2026 with bail bond accepted on identical terms. Search terms: modification of bail/bail-bond condition, substitution of bailor/surety, anticipatory bail conditions, Criminal Miscellaneous No.68761 of 2025, Criminal Miscellaneous No.48646 of 2025, PS Case No.147/2023 (Parihar, Sitamarhi).

What did the court decide?

Bail condition modified: mother Madina Khatoon substituted as bailor in place of the petitioner's deceased father; if the petitioner surrenders on or before 30.01.2026, his bail bond shall be accepted on the same terms and conditions.

Why is it important?

Modification application allowed: the order dated 11.08.2025 in Criminal Miscellaneous No.48646 of 2025 stands modified so that one of the petitioner's bailors shall be his mother Madina Khatoon instead of his father. ¶17

What the court decided

AI extract

Outcome

Bail condition modified: mother Madina Khatoon substituted as bailor in place of the petitioner's deceased father; if the petitioner surrenders on or before 30.01.2026, his bail bond shall be accepted on the same terms and conditions.

Issue for consideration

Whether the condition in the anticipatory bail order dated 11.08.2025 requiring one of the petitioner's bailors to be his father should be modified/removed in view of the father's earlier death.

Ratio / Principle

Modification application allowed: the order dated 11.08.2025 in Criminal Miscellaneous No.48646 of 2025 stands modified so that one of the petitioner's bailors shall be his mother Madina Khatoon instead of his father.

Key takeaways

If the petitioner surrenders on or before 30.01.2026, his bail bond shall be accepted on the same terms and conditions, with the bailor now being his mother.ratio¶17

Detailed headnote1 paragraphs

Anticipatory bail - modification of bail condition - condition that one of the petitioner's bailors shall be his father deleted; mother Madina Khatoon substituted as bailor. The father had died on 05.06.2023 (death certificate on record as Annexure-P/3), and the word 'Late' had been inadvertently omitted before his name while describing the petitioner in the earlier order dated 11.08.2025 in Criminal Miscellaneous No.48646 of 2025. If the petitioner surrenders on or before 30.01.2026, his bail bond shall be accepted on the same terms and conditions. (Patna High Court, Satyavrat Verma, J.; Cr. MISC. No.68761 of 2025 arising out of PS Case No.147 of 2023, Parihar PS, Sitamarhi.)

A

IN THE HIGH COURT OF JUDICATURE AT PATNA CRIMINAL MISCELLANEOUS No.68761 of 2025

In

CRIMINAL MISCELLANEOUS No.48646 of 2025

Arising Out of PS. Case No.-147 Year-2023 Thana- PARIHAR District- Sitamarhi

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

Md. Firoj @ Firoj Son of Late Md. Sultan @ Late Md. Sultan Ansari (Sultan Momin) Village- Bhawanipur ward no. 12,Ps- Parihar, Dist- sitamarhi

... ... Petitioner/s

Versus

The State of Bihar

... ... Opposite Party/s ====================================================== Appearance : For the Petitioner/s : Mr. Uday Kumar, Advocate For the Opposite Party/s : Mr. Mithlesh Kumar Khare, APP ======================================================

CORAM: HONOURABLE MR. JUSTICE SATYAVRAT VERMA ORAL ORDER

6 09-01-2026

Heard learned counsel for the petitioner and learned APP for the State.

Learned counsel for the petitioner submits that petitioner was granted the privilege of anticipatory bail by an order dated 11.08.2025 in Criminal Miscellaneous No.48646 of 2025 with a condition that one of the bailors of the petitioner shall be his father. It is next submitted that the instant modification application has been filed seeking modification of the order dated 11.08.2025 in Criminal Miscellaneous No.48646 of 2025 to the extent that the condition of bailor be removed as father of the petitioner died much earlier and inadvertently the word ‘Late’ could not be prefixed before the name of the father of the petitioner while describing the petitioner. It is further

Patna High Court CR. MISC. No.68761 of 2025(6) dt.09-01-2026 2/2

submitted that in the modification application, a supplementary affidavit has been filed bringing on record the death certificate of the father of the petitioner annexed as Annexure-P/3 and from perusal of the same, it would manifest that father of the petitioner died on 05.06.2023.

In view of the submissions made by learned counsel for the petitioner, the modification application is allowed and the order dated 11.08.2025 in Criminal Miscellaneous No.48646 of 2025 is modified to the extent that one of the bailors of the petitioner shall be his mother, namely, Madina Khatoon instead of father. It is made clear that if petitioner surrenders on or before 30.01.2026, in that event, his bail bond shall be accepted on the same terms and conditions. It is also made clear that bailor of the petitioner now shall be his mother as recorded hereinabove.

(Satyavrat Verma, J)

Sanjay/-

U T

Issues for consideration

1 issue framed by the court

AI extract

1.
Whether the condition in the anticipatory bail order dated 11.08.2025 requiring one of the petitioner's bailors to be his father should be modified/removed in view of the father's earlier death.¶14

Procedural history

How this case reached the court

AI extract

Order under challenge
Order dated 11.08.2025 in Criminal Miscellaneous No.48646 of 2025 granting anticipatory bail to the petitioner subject to the condition that one of his bailors shall be his father; the present application sought modification/removal of that bailor condition.¶14
Patna High Court · 11.08.2025
Prior proceeding
Underlying police case: PS Case No. 147 of 2023, Parihar police station, Sitamarhi district.¶4
Prior proceeding
Instant modification application (Criminal Miscellaneous No.68761 of 2025) filed to remove the bailor condition, as the father had died much earlier and the word 'Late' had been inadvertently omitted before his name while describing the petitioner.¶14
Prior proceeding
Supplementary affidavit filed in the modification application annexing the father's death certificate as Annexure-P/3, showing the father died on 05.06.2023.¶16

Parties & counsel

AI extract

petitioner
Md. Firoj @ Firoj Son of Late Md. Sultan @ Late Md. Sultan Ansari (Sultan Momin)¶6
Uday Kumar
respondent
The State of Bihar¶9
Mithlesh Kumar Khare

Coram

AI extract

Satyavrat Vermaauthor¶11

Case details

As recorded by the court registry

Court: Patna HC
Decided on: 9 Jan 2026 · January
Registered: 18 Sept 2025
Case no.: CR. MISC./68761/2025
CNR: BRHC010970292025
Bench: Satyavrat Verma
Disposal: DISPOSED
Case type: Criminal Miscellaneous

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Cite this judgement

Md. Firoj @ Firoj v. The State of Bihar, CR. MISC./68761/2025 (PAT), decided on 9 January 2026.

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

Procedural history4

Order dated 11.08.2025 in Criminal Miscellaneous No.48646 of 2025 granting anticipatory bail to the petitioner subject to the condition that one of his bailors shall be his father; the present application sought modification/removal of that bailor condition.Patna High Court · 11.08.2025
Underlying police case: PS Case No. 147 of 2023, Parihar police station, Sitamarhi district.
Instant modification application (Criminal Miscellaneous No.68761 of 2025) filed to remove the bailor condition, as the father had died much earlier and the word 'Late' had been inadvertently omitted before his name while describing the petitioner.

View full history

Bench / Coram

Satyavrat Verma

Parties & counsel