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Patna High Court

Archana Devi @ Ram Dulari DeviversusThe State of Bihar

Decided
Disposal
BAIL GRANTED

Holding

The court granted anticipatory bail to the petitioners subject to conditions under Section 482(2) of the B.N.S.S.

Summary

The petitioners, Archana Devi and Puja Devi, sought relief from imminent arrest in a dowry‑related murder case (PS Case No.190 of 2025) where they were alleged to have tortured the informant's daughter, leading to her death. The prosecution alleged that the petitioners, along with other co‑accused, demanded dowry and inflicted torture when the demand was not met. The petitioners contended they are innocent, are sisters‑in‑law of the deceased, have lived separately for three years, have no prior complaints against them, and possess clean antecedents. The court noted the relationship of the petitioners to the deceased, the non‑specific nature of the allegations, the anticipatory bail already granted to other co‑accused, and the possibility of false implication. Accordingly, the court granted anticipatory bail to the petitioners on furnishing a bail bond of Rs.10,000 with two sureties and subject to conditions under Section 482(2) of the B.N.S.S.

Issues considered

  • Whether anticipatory bail should be granted to the petitioners in view of the allegations of dowry‑related torture and murder
  • Whether the petitioners can be considered falsely implicated given their relationship to the deceased and lack of prior complaints

Subjects

  • anticipatory bail
  • dowry death
  • false implication
  • criminal procedure
  • Section 482
  • Section 80
  • Section 3(5)
  • Bihar

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.16223 of 2026
                   Arising Out of PS. Case No.-190 Year-2025 Thana- BOCHAHAN District- Muzaffarpur
                 ======================================================
           1.     Archana Devi @ Ram Dulari Devi wife of Jeetu Paswan Resident of Village
                  -Salha, Ward No 13, PS -Bochahan, Distt -Muzaffarpur
           2.    Puja Devi @ Puja Kumari Wife of Manjeet Paswan Resident of Village
                 -Salha, Ward No 13, PS -Bochahan, Distt -Muzaffarpur

                                                                                 ... ... Petitioner/s

                                                      Versus

                 The State of Bihar

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :      Mr.Pradeep Kumar Sinha, Advocate
                 For the Opposite Party/s :      Mr.Shailendra Kumar, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE ARUN KUMAR JHA
                                       ORAL ORDER

2   06-04-2026                    Heard learned counsel for the petitioners and learned

                   APP for the State.

                                   2. In the present case, the petitioners are

                   apprehending their arrest in connection with Bochahan

                   (Muzaffarpur) P.S. Case No. 190 of 2025 registered for the

                   offences under Sections 80 and 3(5) of B.N.S.

                                      3. As per prosecution case, the petitioners and

                   other co-accused persons tortured the daughter of the informant

                   for demand of dowry as the daughter of the informant was

                   married with co-accused Sanjeet Paswan. On non-fulfillment of

                   the demand, the daughter of the informant was variously

                   tortured by the petitioners and other co-accused persons.
Patna High Court CR. MISC. No.16223 of 2026(2) dt.06-04-2026
                                            2/3




          Ultimately, just after one year of the marriage, the daughter of

          the informant was killed in her matrimonial home.

                            4. Learned counsel for the petitioners submits that

          the petitioners are innocent and have falsely been implicated in

          this case. The petitioners are sisters-in-law (Gotni) of the

          deceased and the Mukhiya of the concerned village has given a

          certificate that they are living separately along with their

          husband from the husband of the deceased for last three years

          and they have no connection with the deceased and her husband.

          Nothing has come on record that any complaint was earlier

          made regarding the demand of dowry by the petitioners and

          other co-accused persons. The co-accused husbands/ brothers-

          in-law of the deceased have been granted anticipatory bail by

          learned Co-ordinate Bench vide order dated 04.02.2026 passed

          in Cr. Misc. No. 6378 of 2026. The petitioners are having clean

          antecedent.

                       5. Learned APP opposes the submission made on

          behalf of the petitioners.

                       6. Having regard to the facts and circumstances and

          submissions made on behalf of the parties and considering the

          relationship of the petitioners with the deceased and further

          considering the general and non-specific nature of allegation
            Patna High Court CR. MISC. No.16223 of 2026(2) dt.06-04-2026
                                                        3/3




                      and grant of anticipatory bail to the co-accused husband of the

                      petitioners and further considering the possibility of false

                      implication, let the petitioners above named, in the event of their

                      arrest or surrender before the court concerned within a period of

                      eight weeks from today, be released on bail, on furnishing bail

                      bonds of Rs.10,000/- (Rupees Ten Thousand Only) each with

                      two sureties of the like amount each to the satisfaction of

                      learned A.C.J.M. 9th, (East), Muzaffarpur/concerned court in

                      connection with Bochahan (Muzaffarpur) P.S. Case No. 190 of

                      2025, subject to the condition as laid down under Section 482(2)

                      of the B.N.S.S. and other following conditions :

                                                      (i) One of the bailors will be a close

                                                      relative of the petitioners.

                                                      (ii) The petitioners will remain present

                                                      on each and every date fixed by the

                                                      court below, if so required by the

                                                      learned trial court.



                                                (Arun Kumar Jha, J)

    DKS/-

U       T


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