Patna High Court

Triveni Sahu @ Triveni PrasadversusThe State of Bihar

Decided: 18 February 2026
Disposal: ALLOWED
Bench: ASHOK KUMAR PANDEY

Holding

The court granted regular bail to the petitioner.

Summary

The petitioner, Triveni Sahu, sought regular bail in a criminal case (PS Biraul Case No. 364 of 2025) involving alleged dowry-related cruelty and the murder of the informant's daughter. The prosecution alleged that the victim was killed by her in‑laws after a dowry demand of Rs.5 lakh was not met, invoking sections 61(2), 80, 238 and 3(5) of the B.N.S. The petitioner, the victim's brother‑in‑law, claimed innocence, no prior criminal record, and highlighted that a co‑accused had already been granted bail. The State opposed the bail application. After hearing both sides, the court found no compelling reason to deny bail and ordered the petitioner released on a bail bond of Rs.10,000 with two sureties.

Issues considered

Whether the petitioner is entitled to regular bail under sections 61(2), 80, 238 and 3(5) of the B.N.S. in a dowry‑death murder case
Whether the seriousness of the alleged offence and the petitioner’s custody since 28‑09‑2025 preclude bail

Legislation cited

B.N.S. — s. 238, 3(5), 61(2), 80

Subjects

bail
dowry death
cruelty
murder
B.N.S.
sections 61(2)
section 80
section 238
section 3(5)
criminal procedure

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.11288 of 2026
                      Arising Out of PS. Case No.-364 Year-2025 Thana- BIRAUL District- Darbhanga
                 ======================================================
                 Triveni Sahu @ Triveni Prasad Son of Kumar Sahu Resident of - Dumri
                 Zeromile, P.S.- Biraul, Darbhanga, Bihar. Permanent Resident of Ward No.
                 11, Gosava Mohiuddipur, P.S.- Alinagar, District - Darbhanga, Bihar, Pin -
                 847103



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


                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :       Ms. Smiti Bharti, Advocate
                 For the Opposite Party/s :       Mr. Uday Pratap Singh, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE ASHOK KUMAR PANDEY
                                       ORAL ORDER

2   18-02-2026                    Heard learned counsel for the petitioner, learned

                   APP for the State and learned counsel for the informant.

                                2. The petitioner has prayed for regular bail in a case

                   registered for the offence punishable under sections 61(2), 80,

                   238 and 3(5) of B.N.S.

                                3. The case of the prosecution is that the daughter of

                   the informant, namely, Pushpa Kumari was married to Pramod

                   Prasad. It is alleged that after marriage, she was being

                   subjected to cruelty on account of non-fulfillment of dowry

                   demand of Rs. 5 lacs. It is further alleged that a panchayati was

                   also held but the in-laws of the deceased were not ready. On
Patna High Court CR. MISC. No.11288 of 2026(2) dt.18-02-2026
                                            2/3




          27.09.2025, the in-laws have killed the daughter of the

          informant. When the informant reached the matrimonial house

          of the deceased, police prepared inquest and body was sent for

          postmortem.

                       4. Learned counsel for the petitioner submits that the

          petitioner is innocent and has committed no offence. Learned

          counsel for the petitioner has submitted that the petitioner is

          brother-in-law of the deceased and the nature of allegation is

          general and omnibus. A statement has been made in para-3 of

          this petition that the petitioner has got no criminal antecedent.

          Moreover, the petitioner is languishing in judicial custody

          since 28.09.2025. Similarly situated other co-accused person

          has already been granted bail by this court vide Cr. Misc. No.

          4978 of 2026.

                       5. Learned APP appearing for the State and learned

          counsel for the informant have vehemently opposed the prayer

          of regular bail.

                       6. Having heard learned counsel for the parties and

          considering the facts and circumstances of the case, this court

          is inclined to enlarge the petitioner on bail. The above named

          petitioner is directed to be released on bail in connection with

          Biraul P.S. Case No. 364 of 2025 on furnishing bail bond of
             Patna High Court CR. MISC. No.11288 of 2026(2) dt.18-02-2026
                                                         3/3




                       Rs.10,000/- (ten thousand) with two sureties of the like amount

                       each to the satisfaction of learned .C.J.M., Biraul, Darbhanga.



                                              (Ashok Kumar Pandey, J)
lata/-
U        T

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