Supreme Court reverses anticipatory bail rejection order by Justice Anjani Kumar Sharan

In Dharmendra Kumar Singh vs. The State of Bihar & Ors. (2025), Chief Justice B.R Gavai and Justice K. Vinod Chandran passed a 2-page long order dated October 13, 2025 after condoning the delay. The order reads:'' 4. By way of an ad-interim relief, in the event of arrest, the petitioner is directed to be released on
bail...". It added: ''Needless to state that the petitioner will cooperate with the investigation and report to the Investigating Officer as and when directed to do so.'' The SLP (criminal) arose out of impugned final order dated December 2, 2024 by Justice Anjani Kumar Sharan of Patna High Court

In Dharmendra Kumar Singh vs. The State of Bihar & Ors. (2024), Justice Sharan had passed a 2-page long order dated December 2, 2024, wherein, he had concluded:''6. Considering the facts and circumstances of case and the nature of offence, I am not inclined to enlarge the petitioner on anticipatory bail. The prayer for anticipatory bail of the petitioner is hereby rejected.''

The petitioner had approached the High Court apprehending his arrest in Nautan P.S. Case No. 225 of 2023 registered for the offences punishable under Sections 406, 409, 420, 467, 468/34 of the Indian Penal Code. According to the prosecution case, the petitioner along with other co-accused persons are said to have committed fraud of Rs.11 lakh by opening various savings accounts, term deposits, other accounts and issuing fake deposit certificates. 

The senior counsel for the petitioner submitted that the petitioner was innocent and was falsely implicated in this case. The allegation levelled against the petitioner was not specific rather general and omnibus in nature. He submitted that in terms of Clause7 (xii) of the Uttar Bihar Gramin Bank Accountability Policy, the accountability of an employee is: “No accountability will be fixed for any lapse, which has not been pointed out in the two successive audit reports or four years from the date of the event (i.e. occurrence of lapse) whichever is later”. He also submitted that the departmental proceeding was still going on. The petitioner had one criminal antecedent. The APP for the State as well as the counsel for the Regional Manager, Uttar Bihar Gramin Bank, Regional Office, Siwan, Bihar, the opposite party no. 2 had opposed the prayer for anticipatory bail and submitted that the investigation was still going on.