The Registrar General of Patna High Court issued a notice dated June 1, 2026 about the Full Court Farewell Reference at 12 noon on June 4, 2026 in the Centenary Hall of the High Court in the honour of Justice Sangam Kumar Sahoo, the 47th Chief Justice, upon his superannuation on that day after 148 days of his tenure. He is retiring on a day, prior to his 62nd birthday on June 5. Justice Sahoo had joined Patna High Court as Chief Justice on January 7, 2026 which was without Chief Justice since October 22, 2025 after the retirement of Justice P.B. Bajanthri, the 46th Chief Justice. Till June 4, there is likely to be a speculation that Justice Sahoo is likely to be elevated to the Supreme Court.
In the first two judgements dated January 7, 2026 authored by 47th Chief Justice Sangam Kumar Sahoo as part of the Division Bench-I which included Justice Sudhir Singh, the judgments by Justices Satyavrat Verma and Nawneet Kumar Pandey, was upheld in Meera Devi Mantri vs. The State of Bihar through the Secretary of the Department of Animal Husbandry and Fisheries Government of Bihar (2026) and Saroj Kumar Rakshit @ Nanu Da @ Saroj Rakshit @ Nanu Baba vs. The State of Bihar through Additional Chief Secretary, Land and Revenue Department, Government of Bihar (2026) respectively.
In the first month of his tenure, Chief Justice Sahoo's division bench delivered 41 judgements in 24 days. In the second month, his division bench delivered 73 judgements in 24 days. In the third month, it delivered 35 judgements in 21 days. In April 2026, it delivered 96 judgements in 28 days. In May 2026, his bench delivered 10 judgements. During his short tenure, his bench delivered 255 judgements and passed 4175 orders. Most of them were authored by Chief Justice Sahoo.
His bench heard a case based one news report in Hindustan with regard to air pollution load and air quality index in several cities of the State and passed detailed orders. His 30-page long order dated February 12, 2026 recorded the state of air pollution in the State. The order captures the diagnosis but the remedy is nowhere in sight. His orders in this regard will act as a stepping stone.
As the Chief Justice of Patna High Court his last order as part of the Division Bench with Justice Harish Kumar, was passed on May 15, 2026 in Dr. Ranganathan Rajya Pustakalaya Samiti & Anr. vs. The State of Bihar & Ors. (2026), wherein, he concluded:"In the eyes of the law, a vacant librarian post, especially in a University is not merely an administrative oversight; it is seen as a functional breakdown in the "administration of justice" and the "academic health" of an institution. The vacancy of a librarian is not an administrative choice but a failure of the State's duty to provide the necessary infrastructure for education and justice. In the absence of a Librarian, physical collection of books deteriorate without proper preservation protocols, reference services remain absent, institutional subscriptions to journals and databases are not procured, managed, or optimised, and no systematic weeding or collection takes place. 7. With the aforesaid direction and observation, the matter be listed on 06.07.2026." The order was authored by the outgoing chief justice. The case will now be heard by the next chief justice. The case was filed on December 17, 2020 and registered on January 23, 2021. Significantly, five chief justices, namely, Justices Sanjay Karol, K. Vinod Chandran, Vipul Manubhai Pancholi, P.B. Bajanthri and now Sahoo have heard the case since June 2021 but the posts of the librarians have not been filled up. Since 1990, vacancies for the post of librarians in the universities in Bihar have not been filled up. At 289 posts of librarians are lying vacant. Underlining the significance of librarians, Chief Justice Sahoo cited Neil Gaiman, the author of The Graveyard Book who said, “Google can bring you back 1,00,000 answers, a librarian can bring you back the right one."
Justice Sahoo's last judgement was delivered on May 12, 2026 in Sakali Devi vs. The State of Bihar & Anr. (2026), wherein he dealt with an error in reporting death of the appellant. The core legal dispute was the erroneous abatement of a criminal appeal based on an incorrect police report stating the appellant, Sakali Devi, had died. The High Court accepted apology of Rakesh Kumar Sharma, SHO, Tajpur Police Station, SP, Samastipur who reported her to be dead. During a short span of 148 days, his division bench delivered 255 judgements.
Justice Sahoo' second last judgement dated May 7, 2026 was in Siya Singh vs. The State of Bihar through Principal Secretary, Department of Labour, Government of Bihar & Ors. (2026), wherein, he observed: "Labour law is not merely an adjunct of the law of contract; it is a charter of human rights at the workplace. The Government cannot be permitted to play hide and seek with its own employees. To deny a workman his lawful dues by juggling with procedural niceties is to negate the very rule of law." As part of the Division Bench, he set aside the judgement by Justice G. Anupama Chakravarthy. He concluded:"we are of the humble view that when the foundational award has not been challenged before the learned Single Judge, the impugned order disturbing the effect of such award, is not sustainable in the eyes of law. Hence, the impugned order dated 23.06.2025 passed by the learned Single Judge, is hereby set aside."
In April 2026, a Suo Motu Public Interest Litigation was initiated by the Patna High Court's Division Bench led by Justice Sahoo pursuant to the report dated February 17, 2026 submitted by the Member Secretary, Bihar State Legal Services Authority (BSLSA). BALSA's inspection report with respect to the shortcomings of mental health facilities in the State of Bihar as well as in Bihar State Institute of Mental Health and Allied Sciences (BIMHAS), Koelwar, Bhojpur is an independent report. In Court on its own motion Regarding matter relates to the Inspection Report vs. The State of Bihar & Ors. (2026), Justice Sahoo passed a 25-age long order dated May 12, 2026, in the matter of compliance with the provisions of Section 18, 19, 20, 21, and 27 of the Mental Healthcare Act, 2017, pertaining to right to access mental healthcare, right to community living of every person with mental illness, right to protection from cruel, inhuman and degrading treatment, right to equality and non-discrimination of every person with mental illness to be treated as equal to persons with physical illness in the provision of all healthcare and right to free legal aid of persons with mental illness. The 48th Chief Justice is likely to hear this matter which is listed for June 23, 2026.
In a Death Reference No. 1 of 2026, in The State of Bihar vs. Lamboo Sharma (2026), Chief Justice Sahoo authored the 176-page long judgement dated March 26, 2026 on behalf the Division Bench comprising Rajeev Ranjan Prasad, wherein, he reversed the decision of the trial court upon hearing it along with a batch of cases. Notably, the sentence imposed by the trial Court on these two appellants for the offence of trying to escape from police custody under section 224 of the IPC was upheld. Justice Prasad authored the concurring judgement, underlining that the hearing procedure was "a learning experience". The case had arisen from a trial conducted by the Additional Sessions Judge, Bhojpur, Ara. In a 176-page judgment, the Patna High Court set aside the conviction of multiple accused persons in the Ara Civil Court bomb blast case, holding that the prosecution failed to establish the chain of circumstances beyond reasonable doubt and reiterating that “suspicion, however strong, cannot take the place of proof.” In the context of the admissibility of 'electronic evidence", Chief Justice Sahoo observed:"In the case in hand,even though the prosecution has exhibited Call Detail Record (CDR) of the mobile phones seized during investigation to prove the essential metadata like timestamp, call details which includes duration, type (incoming, outgoing, missed), source/destination numbers and device identifiers but since there is no signature of any official, there is no certificate as required under section 65B(4) of the Evidence Act nor any nodal officer of the service provider or any responsible officer in relation to the operation of the relevant device has been examined in this case, in view of the settled position of law as discussed above, the CDR cannot be legally admissible. In this case, it is nonetheless the duty of the prosecution, when found that the requisite certificate is missing in the CDR available in the charge sheet, ought to have applied before the Court making a prayer for summoning a person occupying a responsible official position in relation to the operation of the relevant device or the management of the relevant activities (whichever is appropriate) referred to in section 65B(4) of the Evidence Act to produce the requisite certificate on CDR and after it is so produced, a copy thereof should have been furnished to the accused persons before commencement of the trial so that there would not have been any kind of prejudice to the accused persons since the certificate under section 65B(4) is a condition precedent to the admissibility of the evidence by way of electronic record. Accordingly, we accept the contention raised by the learned Amicus Curiae that all the CDRs exhibited by the prosecution are not admissible in evidence." The quality of the judgement especially with reference to "electronic evidence" is such that it ought to be taught in law schools and judicial academies.
Justice Sahoo was elevated as Judge of the Orissa High Court on July 2, 2014. 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 throughout Odisha in the District Courts, High Court, Consumer Forum, SAT and CAT. He was 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.
Notably, the tenure of the 46th Chief Justice, Justice Bajanthri was merely 32 days. As Chief Justice this was the third shortest in the history of the High Court only behind 1 day tenure of Justice Bhagwati Prasad Jha and 5 day tenure of Justice Sushil Kumar Jha. After retirement, the Supreme Court had designated Bajanthri as a Senior Advocate on December 11, 2025. He is all set to be designated as a Senior Advocate like his predecessor. As an advocate, he used to practice under the guidance of his father, Late Sarat Chandra Sahoo, and Dr. Manoranjan Panda. Now a new crop of advocates will learn under his guidance.
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