Patna High Court has been functioning without a Chief Justice from October 22, 2025. Now Supreme Court Collegium in its meeting held on December 18, 2025 has recommended elevation of Justice Sangam Kumar Sahoo, a judge of Odisha High Court as the Chief Justice of the Patna High Court.
Justice Sahoo was elevated as Judge of the Orissa High Court on July 2, 2014. At present, he is the second senior most judge of the Odisha High Court.
Prior to his arrival in Patna High Court, Justice Sahoo adjudicated the case in Jatia Hembram vs. State of Odisha (2025), as part of the Division Bench which included Justice Sibo Sankar Mishra. The bench passed a 9-page long order dated November 26, 2025. Jatia Hembram, the appellant preferred the appeal to challenge the judgment and order dated January 30, 2013 of the Additional Sessions Judge, Baripada in a S.T. case of 2011 whereby he was convicted for offence under section 302 of I.P.C. and sentenced him to undergo imprisonment for life.
Justice Sahoo led bench observed:"A right of appeal is an invaluable right, particularly for an accused who cannot be condemned eternally by a trial Judge, without having a right to seek a re-look of the trial Court's judgment by a Superior or Appellate Court. The right to prefer an appeal by an accused against the conviction is not merely a statutory right but can also be construed to be a fundamental right under Articles 14 and 21 of the Constitution. When a convict is in judicial custody and not having the financial capacity to challenge the conviction order by way of an appeal making his own arrangement, it becomes the sacrosanct duty of authorities concerned to provide legal aid to him and to ensure that the appeal is filed with promptitude and information in that respect with up to date status of the appeal is provided to the convict regularly. Sometimes, the convicts are unaware of their legal rights or appeal process and sometimes, they expressed unwillingness and are reluctant to file appeals for various reasons. If any convict does not choose to prefer appeal against his conviction in spite of proper guidance and proper advice being aware of his fundamental and statutory rights, the same should be obtained in writing from him by the Secretary of the D.L.S.A. and be forwarded to the Member Secretary of Odisha State Legal Services Authority for future reference and a copy of the same shall also be kept with the jail authorities. The convict should be guided properly and provided suitable advice regarding the statutory and constitutional rights to prefer the appeals, if necessary by taking the help of their family members so that appeals can be instituted with their consent."
He relied on Supreme Court's decision in Kamaljit Kaur vs. State of Punjab reported in 2025 LiveLaw (SC) 1035 that the appeal filed without the convict’s consent amounted to a misuse of process of law. Therefore, it is necessary that the convict’s refusal to give his consent to prefer an appeal should be obtained in writing. Since the legal system provides a robust right to appeal, the convicts, who are unable to make their own arrangement in preferring the appeals against the conviction, should receive free and effective legal aid as part of their right to access justice.
Justice Sahoo concluded:"Considering the poor financial condition of the appellant, the period of his detention in judicial custody and the circumstances under which the Jail Criminal Appeal could not be filed earlier and since the appellant has been sentenced to undergo imprisonment for life, taking a liberal view, we are inclined to condone the delay in filing the JCRLA. Accordingly, the delay is condoned."
Justice Sahoo did his LL.B. from The Law College, Cuttack. He enrolled as an Advocate on November 26, 1989 under Orissa State Bar Council, Cuttack. He started practice under the guidance of his father Sarat Chandra Sahoo, Advocate who was a renowned criminal law practitioner and Dr. Manoranjan Panda, Advocate, a service and constitutional law expert.
Justice Sahoo has practiced criminal law and service matter.He has practiced through out Odisha in the District Courts, High Court, Consumer Forum, SAT and CAT. He as born on June 5, 1964. He did his Matriculation from Nuabazar High School, Cuttack, ISc., B.Sc. from Stewart Science College, Cuttack and M.A. (English) and M.A. (Oriya) from Utkal University, Bhubaneswar.
It may be recalled that in exercise of the powers under Section 113 of the Government of India Act, 1915, the King of the United Kingdom had issued letters of patent dated February 9, 1916to constitute the Patna High Court. Odisha was placed under the jurisdiction of Patna High Court. Although on May 18,1916, Circuit Court of Patna High Court for Odisha held its first sitting at Cuttack.
On April 1, 1936, Odisha was made a separate province but no separate High Court was provided for it. The Government of India agreed to create a new High Court, and for that purpose the Government of India issued the Odisha High Court Order, 1948, under the Section 229 (1) of the Government of India Act, 1935, on 30 April 1948. On July 26,1948, Odisha High Court was formally inaugurated prior to adoption of the Constitution of India on November 26, 1949 by which the Government of India Act, 1935 was repealed.
Justice Saboot comes from a High Court which has a Museum of Justice. During his tenure, Patna High Court may also get a similar Museum.
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