Patna High Court

Ramashray ChauhanversusThe State of Bihar

Decided: 22 January 2026
Disposal: BAIL GRANTED
Bench: NAWNEET KUMAR PANDEY

Holding

The court granted regular bail to the petitioners subject to bond and surety conditions.

Summary

The petitioners, Ramashray Chauhan and Urmila Devi, applied for regular bail in a 2013 case (PS Manpur No.61) involving alleged offences under Sections 304(b), 201 and 34 of the Indian Penal Code, relating to the dowry‑death of Sona Devi. The FIR was lodged by the deceased's mother, alleging that the accused strangulated the victim for non‑payment of a Rs.50,000 dowry demand. The petitioners contended they were falsely implicated, have clean antecedents, and that the husband of the deceased had already been granted bail, indicating a stronger footing for their own bail. The prosecution opposed bail, relying on witness statements supporting the occurrence of the crime. After considering the facts, the court directed that bail be granted on furnishing a bond of Rs.10,000 each with two sureties of equal amount, subject to the condition of cooperation with the trial.

Issues considered

Whether regular bail should be granted to the petitioners accused under Sections 304(b), 201 and 34 IPC in a dowry‑death case
Whether the petitioners pose a risk of fleeing, tampering with evidence or influencing witnesses

Legislation cited

Indian Penal Code — s. 201, 304(b), 34

Subjects

regular bail
dowry death
IPC
Section 304(b)
Section 201
Section 34
criminal procedure
bail conditions

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.1648 of 2026
                       Arising Out of PS. Case No.-61 Year-2013 Thana- MANPUR District- Nalanda
                 ======================================================
           1.     Ramashray Chauhan S/O Late Basudeo Chauhan R/O Village- Vishunpur,
                  P.S.- Manpur, District-Nalanda
           2.     Urmila Devi W/O Surendra Chauhan R/O Village- Vishnupur, P.S.- Manpur,
                  District-Nalanda
                                                                          ... ... Petitioner/s
                                                Versus
                 The State of Bihar                                ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :       Mr.Raj Kishor Prasad
                 For the Opposite Party/s :       Mr.Dr. Kumar Uday Pratap
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE NAWNEET KUMAR
                 PANDEY
                                       ORAL ORDER

2   22-01-2026                   Heard the learned counsel for the petitioners as well as

                   the learned Additional Public Prosecutor for the State.

                                2. The petitioners are seeking regular bail in connection

                   with Manpur P.S. Case No. 61 of 2013, registered for the offences

                   punishable under Sections 304(B), 201, 34 of the IPC.

                                3. The informant is mother of the deceased. She lodged

                   an FIR stating therein that the second marriage of her daughter,

                   Sona Devi, was solemnized with co-accused Surendra Chauhan.

                   The accused persons strangulated her to death due to non-

                   fulfillment of the demand of dowry of Rs. 50,000/-.

                                4. The learned counsel for the petitioners has submitted

                   that the petitioners are innocent and have falsely been implicated

                   in this case. Petitioner no. 1 is the father-in-law of the deceased,

                   whereas petitioner no. 2 is the sautan (the first wife of Surendra
           Patna High Court CR. MISC. No.1648 of 2026(2) dt.22-01-2026
                                                       2/2




                     Chauhan). They are persons of clean antecedents and have been in

                     custody since 07.11.2025. He has further submitted that the

                     husband of the deceased has been granted bail and the case of the

                     petitioners is on better footing.

                                  5. On the other hand, the learned counsel for the

                     informant has opposed the prayer for bail and submitted that the

                     witnesses in paragraph nos. 5, 6, 231 and 232 of the case diary

                     have supported the occurrence.

                                  6. The husband of the deceased has been granted bail,

                     and the case of the petitioners is on better footing.

                                  7.   Considering        the    above-mentioned   facts   and

                     circumstances, let the petitioners above-named, are directed to

                     furnish bail bond and on doing so, the court below shall release the

                     petitioners on bail on furnishing bail bonds of Rs.10,000/- each

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

                     learned CJM, Nalanda, Biharsharif/Concerned Court in connection

                     with Manpur P.S. Case No. 61 of 2013, subject to the following

                     conditions that the petitioners shall cooperate in the disposal of

                     trial and make themselves available as and when required by the

                     court.


                                          (Nawneet Kumar Pandey, J)
Nirmal/-
U      T

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