Patna High Court

Sunil Agrawal @ Sunil Agarwal @ Sunil Kumar @ Sunil Kumar AgrawalversusThe State of Bihar

Decided: 12 March 2026
Disposal: ALLOWED
Bench: ASHOK KUMAR PANDEY

Holding

The court granted regular bail to the petitioner.

Summary

The petitioner, Sunil Agrawal, sought regular bail in a criminal case (PS Case No. 379 of 2025) alleging offences under Sections 103(1), 238(1) and 3(5) of the BNS. The prosecution alleged that the deceased, wife of Priyam Agrawal, was strangulated and that the petitioner, along with others, fabricated a suicide. The petitioner’s counsel argued that the FIR only implicates the husband in a matrimonial dispute and that there is no direct allegation against the petitioner, who is the father‑in‑law and has been in judicial custody since 14‑12‑2025. The State opposed bail. Considering the facts, the court found no substantive basis to deny bail and ordered the petitioner’s release on a bail bond of Rs.10,000 with two sureties.

Issues considered

Whether regular bail can be granted to the petitioner despite allegations of involvement in a homicide disguised as suicide under Sections 103(1), 238(1) and 3(5) of the BNS.

Legislation cited

BNS — s. 103(1), 238(1), 3(5)

Subjects

regular bail
criminal procedure
murder
suicide
matrimonial dispute
BNS
Sections 103, 238, 3

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.13775 of 2026
                    Arising Out of PS. Case No.-379 Year-2025 Thana- KASIMBAZAR District- Munger
                 ======================================================
                 Sunil Agrawal @ Sunil Agarwal @ Sunil Kumar @ Sunil Kumar Agrawal
                 S/o- Late Jagarnath Pd. Agarwal Village- Puraniganj Durga Asthan, Kasim
                 Bazar, District- Munger.

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :      Mr. N.K. Agrawal. Sr. Advocate
                                                 Mr. Vijay Anand, Advocate
                 For the Opposite Party/s :      Mr. Nityanand, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE ASHOK KUMAR PANDEY
                                       ORAL ORDER

2   12-03-2026                   Heard learned Senior 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 103(1),

                   238(1) & 3(5) of the BNS.

                                 3. The case of the prosecution, in short, is that police

                   has received information that some lady has committed suicide

                   at Puraniganj. For the verification of this information, police

                   reached the place of occurrence and it has come that the

                   deceased was wife of one Priyam Agrawal and it is further

                   alleged that from perusal of the post-mortem report it is clear

                   that it is not the case of hanging rather it is a case of

                   strangulation and of throttling. It has also come that there was
Patna High Court CR. MISC. No.13775 of 2026(2) dt.12-03-2026
                                            2/3




          dispute between the deceased and her husband on matrimonial

          issues and on the date of the occurrence also, some dispute has

          taken place. It is alleged that the petitioner along with others

          have killed the deceased and have given it a colour of suicide. A

          U.D. case was registered.

                       4. Learned Senior counsel for the petitioner submits

          that from perusal of the FIR it is clear that it is a case of

          matrimonial dispute wherein it is alleged that the daughter-in-

          law of the petitioner has committed suicide whereas according

          to police it is a case of throttling. Learned Senior counsel for the

          petitioner has further submitted that in any view of the matter,

          the petitioner is the father-in-law of the deceased and there is no

          direct allegation against him. Learned Senior counsel for the

          petitioner has further submitted that the main thrust of allegation

          is against the husband. Learned Senior counsel for the petitioner

          has lastly submitted that the petitioner is in judicial custody

          since 14.12.2025.

                       5. Learned APP appearing for the state has opposed

          the prayer of regular bail.

                       6. Considering the aforesaid 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
            Patna High Court CR. MISC. No.13775 of 2026(2) dt.12-03-2026
                                                        3/3




                      bail in connection with Kasim Bazar P.S. Case No. 379 of 2025

                      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., Munger.



                                            (Ashok Kumar Pandey, J)
durgesh/-

U      T

Continue reading with your account

Checking your session…