Patna High Court

Rohit Kumar @ Ramnath Sao @ Rohit SaoversusThe State of Bihar

Decided: 25 February 2026
Disposal: ALLOWED
Bench: ASHOK KUMAR PANDEY

Holding

The court held that the petitioner is entitled to regular bail and ordered his release upon furnishing the required bond.

Summary

The petitioner, Rohit Kumar, was charged under Sections 304B and 34 of the Indian Penal Code for the alleged dowry‑related death of his wife, Renu Kumari. The prosecution alleged that the deceased was strangulated by her in‑laws over unmet dowry demands. The petitioner contended that he was innocent, that the death was a suicide, and highlighted the post‑mortem finding of a ligature mark with no other ante‑mortem injuries. He also pointed out his lack of criminal antecedents and his prolonged pre‑trial detention since September 2024. After hearing both sides, the Patna High Court found the evidence insufficient to deny bail and ordered his release on regular bail upon furnishing a bond with sureties.

Issues considered

Whether the petitioner is entitled to regular bail in a case punishable under IPC Sections 304B and 34.
Whether the circumstances of the death, as indicated by the post‑mortem report, justify a presumption of suicide over homicide.
Whether the petitioner poses a flight risk or threat to the investigation warranting denial of bail.

Legislation cited

Indian Penal Code — s. 304B, 34

Subjects

dowry death
IPC 304B
common intention
regular bail
suicide claim
ligature mark

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.12757 of 2026
                    Arising Out of PS. Case No.-345 Year-2024 Thana- MUFFASIL District- Aurangabad
                 ======================================================
                 Rohit Kumar @ Ramnath Sao @ Rohit Sao Son of Umesh Sao @ Umesh Saw
                 Resident of Vill. - Naghara, P.S. -Aurangabad(Muffasil), Dist. -
                 Aurangabad(Bihar).

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :       Mr. Adarsh Singh, Advocate
                 For the Opposite Party/s :       Mr. Shantanu Kumar, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE ASHOK KUMAR PANDEY
                                       ORAL ORDER

2   25-02-2026                    Heard learned counsel for the petitioner and learned

                   APP for the State.

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

                   registered for the offence punishable under sections 304(B) and

                   34 of the Indian Penal Code.

                                3. The case of the prosecution is that one Renu

                   Kumari (deceased) was married to the petitioner. It is alleged

                   that she was subjected to cruelty on account of non-fulfillment

                   of dowry demand of gold chain and a pulsar bike by her in-

                   laws . Due to non-fulfillment of the said demand, the deceased

                   was strangulated to death by her in-laws.

                                4. Learned counsel for the petitioner submits that the

                   petitioner is innocent and has committed no offence. Learned
Patna High Court CR. MISC. No.12757 of 2026(2) dt.25-02-2026
                                            2/3




          counsel for the petitioner has submitted that the petitioner is the

          husband of the deceased. From perusal of the FIR, it is clear that

          the nature of allegation is general and omnibus. He has further

          submitted that from perusal of the order of the learned trial

          court, it is clear that the learned trial court has recorded that the

          postmortem report of the deceased shows a ligature mark

          present between chin and hyoid in neck in circling around in

          front and absent near the right angle of mandible and back 2” in

          width and 9” in length and the cause of death has been opined

          by the doctor due to asphyxia as a result of antemortem hanging.

          Learned counsel has further submitted that save and except a

          ligature mark on the neck of the deceased, no antemortem injury

          was found on the person of deceased. He has also submitted that

          it is a case of suicide. A statement has been made in para-3 of

          this petition that the petitioner has got no criminal antecedent.

          Moreover, he is languishing in judicial custody since

          25.09.2024.

                       5. Learned APP appearing for the State has

          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
            Patna High Court CR. MISC. No.12757 of 2026(2) dt.25-02-2026
                                                        3/3




                      petitioner is directed to be released on bail in connection with

                      Aurangabad (Muffasil) P.S. Case No. 345 of 2024 on furnishing

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

                      like amount each to the satisfaction of learned C.J.M.,

                      Aurangabad, Bihar.



                                            (Ashok Kumar Pandey, J)
Shubham/-

U     T

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