Patna High Court

Triloki RamversusThe State of Bihar

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

Holding

The court granted bail to the petitioner subject to a bond and sureties under Section 482(2) of the BNSS.

Summary

The petitioner, Triloki Ram, sought bail after being implicated in a case under Sections 103(1) and 3(5) of the Bharatiya Nagarik Suraksha Sanhita (BNSS) concerning the death of his sister-in-law. The prosecution alleged that the deceased's husband, Bajrangi Kumar, may have caused her death, while the petitioner, being the brother‑in‑law, was only peripherally connected. The petitioner argued that the allegations were general, that he had no direct involvement, and that the death was natural, emphasizing his clean antecedents. The State opposed bail, contending the seriousness of the offences. The court, after considering the facts and the petitioner's lack of direct involvement, ordered bail on the condition of a Rs.10,000 bond with two sureties, invoking Section 482(2) of the BNSS, and directed surrender within six weeks.

Issues considered

Whether the petitioner is entitled to bail despite being implicated under Sections 103(1) and 3(5) of the BNSS.
Whether the allegations against the petitioner constitute sufficient ground to deny bail.
Application of Section 482(2) of the BNSS in granting bail.

Legislation cited

Bharatiya Nagarik Suraksha Sanhita — s. 103(1), 3(5), 482(2)

Subjects

bail
criminal law
presumption of innocence
section 482
Bharatiya Nagarik Suraksha Sanhita
over‑implication

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.14025 of 2026
                       Arising Out of PS. Case No.-21 Year-2025 Thana- BADHAILA District- Rohtas
                 ======================================================
                 Triloki Ram S/o Dashrath Ram Resident of Village- Kushdhar, P.S.- Baghaila,
                 District- Rohtas
                                                                            ... ... Petitioner/s
                                                 Versus
                 The State of Bihar Bihar
                                                                     ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :       Mr. Ajay Kumar Tiwari, Advocate
                 For the Opposite Party/s :       Mr. Ram Priya Sharan Singh, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE PRABHAT KUMAR SINGH
                                       ORAL ORDER

2   27-04-2026                  Heard learned counsel for the petitioner and the State.

                                2. Petitioner apprehends arrest in a case registered for

                   the offences punishable under Sections 103 (1) and 3 (5) of

                   BNS.

                                3. As per the prosecution case, daughter of informant

                   got married to co-accused Bajrangi Kumar on 06.06.2023 and

                   after marriage she went to her matrimonial house. It is further

                   alleged that on 06.02.2025, co-accused Bajrangi Kumar

                   informed the informant that his daughter had died. Upon

                   reaching the matrimonial house, the informant found her lying

                   dead. The informant harbours a strong suspicion that the

                   accused persons have culpably caused the death of his daughter.

                                4. Learned counsel for the petitioner submits that

                   petitioner is brother-in -law ( bhaisur) of deceased. Allegation is

                   general and omnibus against this petitioner. Petitioner is simply
            Patna High Court CR. MISC. No.14025 of 2026(2) dt.27-04-2026
                                                        2/2




                      victim of over implications. Informant is not an eye witness to

                      the alleged occurrence. As a matter of fact, deceased died a

                      natural death. Petitioner is separate in mess and property and got

                      no concern with the affairs of deceased and her husband. It is

                      further orally submitted that thrust of accusation is against

                      husband of the deceased, who is already in custody. Petitioner

                      claims clean antecedent.

                                   5. Learned counsel for the State opposed the bail

                      petition of the petitioner.

                                   6. Considering the aforesaid facts, and other

                      circumstances of the case, in the event of arrest or surrender

                      within six weeks from today, let the petitioner, as named above,

                      be enlarged on bail on furnishing bail bond of Rs.10,000/-(ten

                      thousand) each with two sureties of the like amount each to the

                      satisfaction of the learned S.D.J.M., Rohtas at Sasaram in

                      connection with Baghaila Police Station Case No. 21 of 2025,

                      subject to the conditions laid down under section 482 (2) of the

                      Bharatiya Nagarik Suraksha Sanhita ( BNSS), 2023.


                                            (Prabhat Kumar Singh, J)

khushbu/-

U      T

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