Patna High Court

Rachna Kumari @ Archana KumariversusThe State of Bihar

Decided: 20 February 2026
Disposal: BAIL REJECTED
Bench: PRABHAT KUMAR SINGH

Holding

Anticipatory bail was denied to the petitioners.

Summary

The petitioners – Rachna Kumari, Uma Shankar Roy and Sarita Devi – who are respectively the sister‑in‑law, father‑in‑law and mother‑in‑law of a woman who died in 2025, applied for anticipatory bail. The prosecution alleges that they, along with other co‑accused, tortured the deceased for dowry and caused her death, an offence punishable under Sections 80 and 3(5) of the Bharatiya Nyaya Sanhita. The petitioners contend they have no involvement in the deceased’s marital affairs and maintain a clean antecedent. The State argued that the deceased died under unnatural circumstances within seven years of marriage in her in‑laws’ house, indicating direct participation of the petitioners. Considering the seriousness of the dowry‑death allegation and the circumstances of the death, the Court rejected the petition for anticipatory bail.

Issues considered

Whether anticipatory bail should be granted to the petitioners accused of dowry death under Sections 80 and 3(5) of the Bharatiya Nyaya Sanhita.

Legislation cited

Bharatiya Nyaya Sanhita — s. 3(5), 80

Subjects

dowry death
anticipatory bail
Bharatiya Nyaya Sanhita
Section 80
Section 3(5)
in‑laws
criminal law

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                               CRIMINAL MISCELLANEOUS No.110 of 2026
                   Arising Out of PS. Case No.-87 Year-2025 Thana- WARISNAGAR District- Samastipur
                 ======================================================
           1.     Rachna Kumari @ Archana Kumari S/o- Uma Shankar Roy @ Uma Prasad
                  Roy @ Uma Shankar Ray R/v- Kusaiya Ps- Warisnagar Dist- Samastipur
           2.    Uma Shankar Roy @ Uma Prasad Roy @ Uma Shankar Ray S/o- Late
                 Thithar Ray R/v- Kusaiya Ps- Warisnagar Dist- Samastipur
           3.    Sarita Devi Uma Shankar Roy @ Uma Prasad Roy @ Uma Shankar Ray
                 R/v- Kusaiya Ps- Warisnagar Dist- Samastipur

                                                                                 ... ... Petitioner/s
                                                      Versus
                 The State of Bihar

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :      Mr. Shubhesh Pandey, Advocate
                 For the Opposite Party/s :      Md. Fahimuddin, A.P.P.
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE PRABHAT KUMAR SINGH
                                       ORAL ORDER

3   20-02-2026                  Heard learned counsel for the petitioners and the

                   State.

                                2. Petitioners apprehend arrest in Warisnagar P. S.

                   Case No. 87 of 2025 registered for the offences punishable

                   under Sections 80, 3(5) of the Bharatiya Nyaya Sanhita.

                                3. It is a case of dowry death. As per the prosecution

                   case, the daughter of informant got married with co-accused

                   Kamlesh Kumar in the year 2022. Later on, these petitioners

                   along with other co-accused persons started subjecting her to

                   torture and harassment for non-fulfillment of demand of dowry

                   and ultimately, accused persons killed the deceased.
            Patna High Court CR. MISC. No.110 of 2026(3) dt.20-02-2026
                                                        2/2




                                   4. Learned counsel for the petitioners submitted that

                      petitioner no. 1 is unmarried sister-in-law, petitioner no. 2 is

                      father-in-law and petitioner no. 3 is mother-in-law of deceased.

                      As a matter of fact, deceased died during treatment on

                      12.01.2025 and after that, panchayati was convened and

                      complaint case was lodged. Petitioners are separate in mess and

                      property and have got no concern with the affairs of deceased

                      and her husband. Thrust of accusation is against husband of the

                      deceased. Petitioners claim clean antecedent.

                                   5. Learned A.P.P. for the State opposed the prayer for

                      bail and submits that petitioners are in-laws of the deceased and

                      there is direct and specific allegation that they along with other

                      co-accused persons killed the deceased due to non-fulfillment of

                      dowry demand. The deceased died in unnatural circumstances

                      within 7 years of marriage in her matrimonial house.

                                   6. Considering the nature of accusation and the fact

                      that deceased died in unnatural condition within 7 years of

                      marriage in her in-laws’ house, prayer for anticipatory bail of

                      the petitioners is rejected.



                                             (Prabhat Kumar Singh, J)
Navya/-
U       T

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