By the order of the Governor of Bihar, Rachna Patil, Secretary (Expenditure). Department of Finance has issued a notification dated June 19, 2026, demoting the Office of Advocate General by deleting it from the list of Heads of Departments under Bihar Service Code. The notification reads: "No. 3A-5-S.C.-05/2013-5777/F. —In exercise of powers conferred by the proviso to Article- 309 of the Constitution of India, the Governor of Bihar is hereby pleased to make the following Amendment in The Bihar Service Code, 1952 with immediate effect:—Amendment "The Office of The Advocate General, Bihar" shall be deleted at S.No.-34 from the list of Heads of Department of the Appendix-3 of the Bihar Service Code."
Notably, this amendment was published in the aftermath of the appointment of Satydarshi Sanjay as the 23rd Advocate General of Bihar from the date on which he took charge. The notification dated June 18, 2026 with regard to his appointment was issued under the signature of Balram Dubey by the order of the Governor of Bihar. S.D. Sanjay, a law graduate from Campus Law Centre, Delhi University was serving as the Additional Solicitor General of India before taking charge as the 23rd AG on June 18, 2026. He has served as Additional Advocate General of Bihar during 2010-2014.
The notification from Balram Dubey, Secretary, Department of Law, Government of Bihar reads:"भारतीय संविधान के अनुच्छेद 165 (1) द्वारा प्रदत्त शक्यिों का प्रयोग करते हुए बिहार के राज्यपाल, श्री एस०डी० संजय (श्री सत्यदर्शी संजय), वरीय अधिवक्ता, उच्च न्यायालय, पटना को उनके पदभार ग्रहण की तिथि से महाधिवक्ता, बिहार के पद पर नियुक्त करते है।" A copy of the communication was sent to 22nd AG at Shahi Bhawan, Shahi Lane, S.P.Verma Road, Patna-800001.
This amendment has been enacted after the resignation of Prashant Kumar Shahi, the 22nd Advocate General (AG) of Bihar on June 15, 2026. Balram Dubey, Secretary, Department of Law, Government of Bihar communicated to the 22nd AG that his resignation has been accepted under instructions from the afternoon of June 15, 2026 vide letter no. 4742.
No one was Advocate General of Bihar for three days because after the resignation of 22nd AG, no one was appointed for three days.
Notably, the details regarding the acceptance of the resignation of the 22nd AG and appointment of teh 23rd AG has been published on the official website of the office of the Advocate General, Bihar, High Court, Patna. The website was developed by the l.T. Department, Government of Bihar, Patna. It was launched on September 22, 2025 at 4:30 pm. The resignation letter has not been published on the website.
Earlier, by the order of Governor of Bihar, The Bihar Service Code, 1952 was amended in exercise of powers conferred by the proviso to Article 309 to elevate the status of Office of The Advocate General, Bihar. The 13th amendment to Bihar Service Code reads: "The Office of The Advocate General, Bihar" shall be added after S.No.-33 at S.No.-34 in the list of Heads of Department of the Appendix-3 of the Bihar Service Code." It was notified in the Bihar Gazette No. 856 on August 28, 2024. It implied that the Advocate General (AG) was deemed as the Head of Department of Government of Bihar. The upgradation of the AG Office into a separate department is a significant institutional change. AG was designated as head of the newly created department. It implied that AG was been granted the status of Cabinet rank minister.
With the 14th amendment in the Bihar Service Code, AG will no more be deemed the head of a department. During the tenure of the 22nd AG, questions were raised in the Bihar State Assembly about the role AG as the 46th Department of Bihar Government but the office of the Speaker, Bihar State Assembly had not allowed those questions.
Notably, Mahabir Prasad was the longest serving AG He was AG for 19 years. Ram Balak Mahto served as AG for 14 years. P.K Shahi served for some 8 years.
The list of former Advocate Generals are as under:
1 Baldeo Sahay 1937 to 1942
2 Jaffar Imam 1942 to 1943
3 Mahabir Prasad 1943 to 1947
4 Laxmi Kant Jha 1948 to 1950
5 Mahabir Prasad 1950 to 1965
6 Lal Narayan Sinha 28-06-1965 to 31-01-1972
7 Balbhadra Prasad Singh 01-02-1972 to 27-09-1976
8 Tara Kant Jha 28-09-1976 to 19-09-1977
9 Krishna Das Chatterjee 20-09-1977 to 16-10-1979
10 Radha Raman 19-10-1979 to 04-04-1980
11 Ram Balak Mahto 05-04-1980 to 09-07-1980
12 Kanhaiya Prasad Verma 10-07-1980 to 04-04-1985
13 Ram Balak Mahto 05-04-1985 to 11-12-1989
14 Kanhaiya Prasad Verma 19-12-1989 to 11-04-1990
15 Ram Balak Mahto 12-04-1990 to 01-12-1993
16 Rameshwar Prasad 02-12-1993 to 31-12-1997
17 Shashi Anugrah Narain 01-01-1998 to 24-11-2005
18 Prashant Kumar Shahi 25-11-2005 to 25-11-2010
19 Ram Balak Mahto 29-11-2010 to 19-02-2015
20 Ram Balak Mahto 27-02-2015 to 28-07-2017
21 Lalit Kishore 31-07-2017 to 10-01-2023
22. Prashant Kumar Shahi 16-01-2023 to 15-06-2026
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