Patna High Court

Hardeo YadavversusThe State of Bihar

Decided: 27 February 2026
Disposal: BAIL GRANTED
Bench: PRABHAT KUMAR SINGH

Holding

The Court granted anticipatory bail to the petitioners subject to the conditions prescribed under Section 482 of the B.N.S.S., 2023.

Summary

The petitioners, who are the father‑in‑law, mother‑in‑law and brother‑in‑law of a woman who was allegedly killed in a dowry‑related case, filed a petition fearing arrest in a case registered under Sections 80(2) and 3(5) of the B.N.S., 2023. The prosecution alleges that the deceased was subjected to cruelty and was strangulated to death by her husband and co‑accused, the husband already being in custody. The petitioners contend they have no involvement in the family affairs, maintain clean antecedents, and seek anticipatory bail. The State opposed the bail. The Court, after considering the facts, granted anticipatory bail to the petitioners, subject to furnishing bail bonds of Rs. 10,000 each with two sureties and compliance with conditions under Section 482 of the B.N.S.S., 2023, provided they surrender within eight weeks.

Issues considered

Whether anticipatory bail can be granted to the petitioners under Section 482 of the B.N.S.S., 2023 in a dowry‑death case.
Whether the petitioners are likely to be implicated in the offence under Sections 80(2) and 3(5) of the B.N.S., 2023.

Legislation cited

B.N.S. — s. 3(5), 80(2)
B.N.S.S. — s. 482

Subjects

anticipatory bail
dowry death
criminal procedure
Section 482
Section 80
Section 3
bail conditions
family dispute

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.13826 of 2026
                    Arising Out of PS. Case No.-299 Year-2025 Thana- PARASBIGHA District- Jehanabad
                 ======================================================
           1.     Hardeo Yadav S/o Late Babulal Yadav R/o Village- Medanichak, P.S-
                  Parasbigha, Dist- Jehanabad.
           2.    Rashmi Devi @ Reshmi Devi W/o Hardeo Yadav R/o Village- Medanichak,
                 P.S- Parasbigha, Dist- Jehanabad.
           3.     Indu Kumar S/o Hardeo Yadav R/o Village- Medanichak, P.S- Parasbigha,
                  Dist- Jehanabad.
                                                                         ... ... Petitioner/s
                                                Versus
                 The State of Bihar
                                                                  ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :        Mr. Krishna Prasad Singh, Senior Advocate with
                                                  1. Vishal Vikram Rana, 2. Misha Bharti, 3. Akash
                                                  Priya, 4. Anurag Darshi, 5. Kumar Saurav Dev and
                                                  6. Utkarsh Vikram Rana, Advocates
                 For the Opposite Party/s :        Mr. Umeshanand Pandit, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE PRABHAT KUMAR SINGH
                                       ORAL ORDER

2   27-02-2026                     Heard Mr. Krishna Prasad Singh, learned senior

                   counsel for the petitioners and Mr. Umeshanand Pandit, learned

                   A.P.P. for the State.

                                 2. The petitioners apprehend their arrest in a case,

                   registered for the offence under Sections 80(2), 3(5) of the

                   B.N.S., 2023.

                                 3. As per prosecution case, daughter of informant was

                   married with co-accused Bindu Kumar on 25.04.2024 and after

                   the marriage, she was subjected to cruelty and harassment by

                   the accused persons for dowry and ultimately, on 19.11.2025,

                   she was killed by the accused persons by strangulation.
           Patna High Court CR. MISC. No.13826 of 2026(2) dt.27-02-2026
                                                       2/2




                                  4. Petitioner no. 1 is father-in-law, petitioner no. 2 is

                     mother-in-law and petitioner no. 3 is brother-in-law of the

                     deceased. There is general and omnibus allegation. Thrust of the

                     accusation is against husband of the deceased, who is already in

                     custody since 01.12.2025. Petitioners are separate in mess and

                     property and have got no concern with the family affairs of

                     deceased and her husband. Petitioners claim clean antecedent.

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

                     anticipatory bail of petitioners.

                                  6. Considering the aforesaid facts and circumstances,

                     let the above named petitioners, in the event of arrest/surrender

                     within a period of eight weeks from today, be enlarged on bail

                     on furnishing bail-bonds of Rs. 10,000/- (ten thousand) each

                     with two sureties of the like amount each to the satisfaction of

                     learned Judicial Magistrate 1st Class, Jehanabad in connection

                     with Parasbigha P.S. Case No. 299 of 2025, subject to condition

                     as laid down under Section 482 of the B.N.S.S., 2023.



                                                      (Prabhat Kumar Singh, J)
anay

U      T

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