Patna High Court
Archana Devi @ Ram Dulari DeviversusThe State of Bihar
- Decided
- Disposal
- BAIL GRANTED
- Bench
- ARUN KUMAR JHA
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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