Patna High Court
Sangeeta DeviversusThe State of Bihar
- Decided
- Disposal
- BAIL GRANTED
- Bench
- PRABHAT KUMAR SINGH
Holding
The court held that the petitioner is entitled to bail under section 482(2) of the B.N.S., 2023.
Summary
The petitioner, Sangeeta Devi, sought bail after being implicated in a dowry‑death case (PS Case No. 349 of 2025) under sections U/s‑103 and 3(5) of the Bharatiya Nagarik Suraksha Sanhita. The prosecution alleged that the petitioner’s daughter‑in‑law was subjected to cruelty and eventually killed for dowry, implicating the petitioner among others. The petitioner’s counsel argued that she is merely the mother‑in‑law of the deceased, has no involvement in the marital affairs, and is a victim of over‑implication, especially since the primary accused husband is already in custody. The State opposed bail. The court, after considering the facts and the provisions of section 482(2) of the B.N.S., ordered that the petitioner be released on bail upon furnishing a bond of Rs.10,000 with two sureties, subject to the usual conditions.
Issues considered
- Whether the petitioner is entitled to bail under section 482(2) of the Bharatiya Nagarik Suraksha Sanhita, 2023 despite the serious nature of the alleged dowry‑death offence.
- Whether the petitioner’s alleged involvement constitutes over‑implication warranting bail.
Legislation cited
- Bharatiya Nagarik Suraksha Sanhita — s. 3(5), U/s-103
- Bharatiya Nagarik Suraksha Sanhita, 2023 — s. 482(2)
Subjects
- bail
- dowry death
- over‑implication
- section 482
- Bharatiya Nagarik Suraksha Sanhita
- criminal procedure
Judgment
IN THE HIGH COURT OF JUDICATURE AT PATNA
CRIMINAL MISCELLANEOUS No.16254 of 2026
Arising Out of PS. Case No.-349 Year-2025 Thana- CHIRAIYA District- East Champaran
======================================================
Sangeeta Devi W/o Ramjinis Giri R/o Village - Semara, P.S - Chiraiya,
District - East Champaran, Motihari
... ... Petitioner/s
Versus
The State of Bihar Bihar
... ... Opposite Party/s
======================================================
Appearance :
For the Petitioner/s : Mr. Dhandev Kumar, Advocate
For the Opposite Party/s : Mr. Md. Mushtaque Alam, APP
======================================================
CORAM: HONOURABLE MR. JUSTICE PRABHAT KUMAR SINGH
ORAL ORDER
3 12-05-2026 Heard learned counsel for the petitioner and the
State .
2. Petitioner apprehends his arrest in a case registered
for the offence punishable under sections U/s-103, 3(5) of
B.N.S.
3 . As per prosecution case , informant alleged that his
daugther was married to co-accused Ranjit Giri in the year
2015 and after sometime of the marriage, she was subjected to
cruelty and torture by all the accused persons named in the
F.I.R., including this petitioner due to non-fulfillment of demand
of dowry. Ultimately, all accused persons killed daughter of
informant for dowry.
4. Mr. Dhandev Kumar, learned counsel for the
petitioner submitted that Petitioner is mother-in -law of husband
Patna High Court CR. MISC. No.16254 of 2026(3) dt.12-05-2026
2/2
of the deceased. She is simply victim of over implications. She
is separate in mess and property and has got no concern with the
affairs of couple . It is further orally submitted that thrust of
accusation is against husband of the deceased who is already in
custody since 07.05.2026 .
5 . Learned counsel for the State opposed the bail
petition .
6 Considering the aforesaid facts, materials available
on record and other circumstances of the case , in the event of
arrest or surrender within eight weeks from today, let the
petitioner, as named above, be enlarged on bail on furnishing
bail bond of Rs.10,000/-(ten thousand) with two sureties of the
like amount each to the satisfaction of the learned S.D.J.M.
Dhaka at East Champaran, Motihari in connection with Chiraiya
P.S. Case No. 349 of 2025, subject to the conditions laid down
under section 482(2) of the Bharatiya Nagarik Suraksha
Sanhita , 2023 .
(Prabhat Kumar Singh, J)
Koushik/-
U T
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