Patna High Court

Manu Ram @ Munna RamversusThe State of Bihar

Decided: 25 February 2026
Disposal: BAIL REJECTED
Bench: CHANDRA SHEKHAR JHA

Holding

The petition for anticipatory bail is dismissed.

Summary

The petitioner, Manu Ram, was named in an FIR for alleged culpable homicide under Sections 304(b) and 34 of the IPC, accused of causing the death of his wife's daughter over a dowry demand. The petitioner’s counsel argued that the death was a suicide by asphyxia, citing the post‑mortem report which showed no external injuries and contending that the dowry demand was vague and the matter was settled between the families. The State opposed anticipatory bail, emphasizing that the death was unnatural, occurred within the matrimonial home, and that the petitioner had failed to explain the cause of death. The court examined the prima facie evidence of an unnatural death in a dowry‑related context and found the petitioner's explanations insufficient. Consequently, the court rejected the petition for anticipatory bail.

Issues considered

Whether anticipatory bail can be granted to a person accused of culpable homicide under Sections 304(b) and 34 of the IPC in a dowry‑related death
Whether the prima facie evidence of an unnatural death within the matrimonial home justifies denial of bail

Legislation cited

Indian Penal Code — s. 304(b), 34

Subjects

anticipatory bail
culpable homicide
dowry death
Section 304(b) IPC
Section 34 IPC
suicide
post‑mortem report
matrimonial home

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.10586 of 2026
                    Arising Out of PS. Case No.-242 Year-2021 Thana- MAHARAJGANJ District- Siwan
                 ======================================================
                 Manu Ram @ Munna Ram S/O Suresh Ram Resident of Village- Akil Tola,
                 P.S.- Maharajganj, Dist.- Siwan.
                                                                    ... ... Petitioner/s
                                                  Versus
                 The State of Bihar
                                                             ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :      Mr.Gajendra Kumar Singh
                 For the Opposite Party/s :      Mr.Zainul Abedin
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE CHANDRA SHEKHAR JHA
                                       ORAL ORDER

3   25-02-2026                    Heard the parties.

                                2. The petitioner is named in the F.I.R. and

                   apprehending his arrest in connection with Maharajganj

                   P.S. Case No. 242 of 2021 registered for the offences

                   punishable under Sections 304(B), 34 of Indian Penal

                   Code.

                                3. The allegation against petitioner is to cause

                   death of daughter of informant due to non fulfillment of

                   demand of dowry.

                                4. It is submitted by learned counsel appearing

                   on behalf of the petitioner that the deceased wife of the

                   petitioner was a short tempered lady and out of her

                   temperamental issues, she committed suicide, which can
Patna High Court CR. MISC. No.10586 of 2026(3) dt.25-02-2026
                                            2/3




          be gathered by the post-mortem report also where the

          cause of death is ascertained “Asphyxia” caused by

          ligature material. It is submitted that upon post-mortem

          no external injury was noticed upon, which prima-facie

          suggests that deceased was not assaulted physically soon

          before the occurrence. It is further submitted that

          demand of dowry is also not appearing specific against

          petitioner rather seems very general and omnibus in

          nature and petitioner implicated with this case only for the

          reason that he is the husband of the deceased. Arguing

          further it is submitted that matter now compromised

          between the parties.

                       5. Learned APP while opposing the prayer of bail

          submitted that occurrence took place within the four

          corners of the matrimonial house of the deceased, where

          petitioner being husband failed to explain the cause of

          death. It is submitted that admittedly the death is

          unnatural within 7 years of marriage in the background of

          dowry allegations and therefore it is not fit case to grant
              Patna High Court CR. MISC. No.10586 of 2026(3) dt.25-02-2026
                                                          3/3




                        anticipatory bail.

                                       6. In view of aforesaid factual and legal

                        submission and by taking note of fact as unnatural death

                        of daughter of informant took place between the four

                        corners of the matrimonial home within seven years of

                        marriage, where petitioner being husband prima-facie

                        failed to explain the cause of death, accordingly the

                        prayer of anticipatory bail of petitioner stands rejected.



                                                                 (Chandra Shekhar Jha, J)
Sudha/-

U         T

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