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Patna High Court

Raviranjan KumarversusThe State of Bihar

Decided
Disposal
DISMISSED

Holding

The Court held that regular bail could not be granted to the petitioner.

Summary

The petitioner, Raviranjan Kumar, was arrested in connection with a dowry death alleged under Sections 103(1), 238 and 3(5) of the Bharatiya Nyaya Sanhita, 2023. He applied for regular bail, claiming innocence and a clean antecedent, having been in custody since 5 October 2025. The State opposed the bail, asserting that prima facie material indicated his involvement in the murder of his wife over dowry demands. The Court examined the FIR and the serious nature of the allegations, particularly the specific charge of dowry death. Concluding that the direct allegation warranted denial of bail, the Court rejected the regular bail application, noting that its observations were only prima facie and would not affect the trial.

Issues considered

  • Whether regular bail should be granted to the petitioner accused of dowry death under Sections 103(1), 238 and 3(5) of the Bharatiya Nyaya Sanhita, 2023

Legislation cited

Subjects

  • bail
  • regular bail
  • dowry death
  • criminal law
  • Bharatiya Nyaya Sanhita
  • Section 103
  • Section 238
  • Section 3(5)

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.17908 of 2026
                   Arising Out of PS. Case No.-212 Year-2025 Thana- PARASBIGHA District- Jehanabad
                 ======================================================
                 Raviranjan Kumar son of Lalbabu Yadav @ Lalbahadur yadav Resident Of
                 Village- Majhanpura Ps -Parasbigha Dist -Jehanabad

                                                                                 ... ... Petitioner/s
                                                      Versus
                 The State of Bihar

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :      Mr. Sunil Kumar
                 For the Opposite Party/s :      Mr. Raj Ballabh Singh
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE SANDEEP KUMAR
                                       ORAL ORDER

2   29-04-2026                  Heard the learned counsel for the petitioner and

                   learned APP for the State.

                                2. The petitioner seeks regular bail in connection with

                   Parasbigha P.S. Case No. 212 of 2025 registered for the offence

                   under Sections 103(1), 238 and 3(5) of the Bharatiya Nyaya

                   Sanhita, 2023.

                                3. As per the prosecution case, the petitioner along

                   with his family members is accused of committing the murder

                   of the deceased due to non-fulfillment of demand of dowry.

                                4. Learned counsel for the petitioner submits that the

                   petitioner is innocent and has not committed any offence.

                   Petitioner is in custody since 05.10.2025 and has clean

                   antecedent.

                                5. Learned counsel for the State vehemently opposes
            Patna High Court CR. MISC. No.17908 of 2026(2) dt.29-04-2026
                                                        2/2




                      the bail application and submits that the allegations against the

                      petitioner are serious and grave in nature. It is contended that

                      there exists prima facie material against the petitioner indicating

                      his involvement in the commission of the offence.

                                   6. I have considered the submissions of the parties and

                      have gone through the records of the case. The main allegation

                      against the petitioner is that he committed dowry death of his

                      wife. There is a specific allegation of dowry death against the

                      petitioner in the FIR.

                                   7. Considering the direct allegation levelled against

                      the petitioner, this Court is not inclined to grant regular bail to

                      the petitioner. Accordingly, this application for regular bail

                      stands rejected.

                                   8. It is made clear that any observation made herein is

                      prima facie in nature and limited solely for the purpose of

                      adjudication of the present bail application. Such observations

                      shall not be construed as an expression on the merits of the case

                      and shall not influence the trial or any other proceedings in any

                      manner.



                                                         (Sandeep Kumar, J)
Shishir/-

U       T


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