Patna High Court

Niranjan KumarversusThe State of Bihar

Decided: 29 April 2026
Disposal: DISMISSED
Bench: PRABHAT KUMAR SINGH

Holding

Anticipatory bail was denied to the petitioner.

Summary

The petitioner, Niranjan Kumar, sought anticipatory bail after being named in an FIR for alleged dowry harassment and the death of his wife, who the prosecution claims was murdered but the petitioner asserts died by suicide. The FIR accuses the petitioner and others of torturing the victim for non‑payment of dowry, invoking Sections 103(1) and 3(5) of the B.N.S. The petitioner contended he is innocent, has a clean record, and was falsely implicated merely because he is the husband of the deceased. The State opposed the bail, emphasizing the specific accusations, the seriousness of the offences, and the petitioner’s marital relationship to the victim. The court examined the gravity of the charges, the direct nature of the allegations, and the public interest in ensuring the petitioner faces trial. Consequently, the court rejected the petition for anticipatory bail, concluding that the circumstances did not warrant such relief.

Issues considered

Whether anticipatory bail should be granted to the petitioner under Sections 103(1) and 3(5) of the B.N.S.
Whether the allegations of dowry harassment and alleged murder justify denial of bail

Legislation cited

B.N.S. — s. 103(1), 3(5)

Subjects

anticipatory bail
dowry harassment
suicide
murder
Section 103
Section 3
High Court
Criminal Procedure

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.16777 of 2026
                       Arising Out of PS. Case No.-296 Year-2025 Thana- MASAUDHI District- Patna
                 ======================================================
                 Niranjan Kumar Son of Mithu Prasad Resident of Village - Visambhar Tola,
                 Kandap, P.S. - Gaurichak, Dist. - Patna.

                                                                                  ... ... Petitioner/s
                                                       Versus

           1.    The State of Bihar
           2.    Pramila Devi W/o Arjun Singh R/o 1A 367 Vidyut Vihar Colony,
                 Shaktinagar Sonbhadra, Uttar Pradesh, at Present R/o Taregna Dih,
                 Masaurhi, Distt. - Patna, 804452.

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner      :        Mr. Akshay Kumar, Advocate
                 For the State           :        Mr. Humayou Ahmad Khan, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE PRABHAT KUMAR SINGH
                                       ORAL ORDER

2   29-04-2026                  Heard learned counsel appearing on behalf of the

                   petitioner and learned A.P.P. appearing on behalf of the State.

                                2. The petitioner apprehends his arrest in a case

                   registered for the offence punishable under Sections 103(1) and

                   3(5) of the B.N.S..

                                3. As per prosecution case, marriage of daughter of

                   informant was solemnized with this petitioner as per Hindu rites

                   and rituals. It is alleged that thereafter, all the F.I.R. named

                   accused persons, including this petitioner, harassed and tortured

                   the victim due to non-fulfillment of demand of dowry and

                   subsequently, committed her murder.
             Patna High Court CR. MISC. No.16777 of 2026(2) dt.29-04-2026
                                                         2/2




                                    4. It is submitted by learned counsel appearing on

                       behalf of the petitioner that petitioner is quite innocent and has

                       falsely been implicated in this case merely because he happens

                       to be husband of the deceased. As a matter of fact, the deceased

                       committed suicide by consuming poison at her parental house.

                       Petitioner claims clean antecedents.

                                    5. On the other hand, learned A.P.P. for the State has

                       vehemently opposed the prayer for grant of anticipatory bail to

                       the petitioner and submitted that petitioner is named in the F.I.R.

                       with specific accusation that he, along with his family members,

                       committed torture and harassment with daughter of informant

                       due to non-fulfillment of demand of dowry due to which, she

                       committed suicide. Petitioner is husband of the deceased who

                       died unnatural death.

                                    6. Considering the facts and circumstances of the

                       case, specific and direct nature of accusation, gravity of offence

                       and the fact that petitioner is husband of deceased, the prayer for

                       grant of anticipatory bail to the petitioner is rejected.



                                             (Prabhat Kumar Singh, J)
shashank/-
U      T

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