Patna High Court

Kundan KumarversusThe State of Bihar

Decided: 24 March 2026
Disposal: DISMISSED
Bench: SANDEEP KUMAR

Holding

The application for regular bail was dismissed.

Summary

The petitioner, Kundan Kumar, applied for regular bail in a criminal miscellaneous proceeding before the Patna High Court. He is charged under Sections 304B and 34 of the Indian Penal Code for the alleged killing of the deceased, a case registered as Madhepura P.S. Case No. 631 of 2024. The petitioner has been in custody since 19 July 2024, and the Sessions Trial in which he was an accused has apparently concluded with a judgment pronounced. The High Court examined the bail application in light of the seriousness of the offence and the fact that the trial had already been completed. The Court dismissed the bail application, refusing regular bail to the petitioner.

Issues considered

What is the appropriate legal standard for granting regular bail to an accused under Sections 304B and 34 of the IPC after the trial has concluded?

Legislation cited

Indian Penal Code — s. 304B, 34

Subjects

regular bail
dowry death
IPC 304B
IPC 34
criminal procedure
high court

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.19034 of 2025
                   Arising Out of PS. Case No.-631 Year-2024 Thana- MADHEPURA District- Madhepura
                 ======================================================
                 Kundan Kumar Son of Suren Mallik @ Suren Malik Resident of Village -
                 Ramnagar, P.S. - Ghailardh, District - Madhepura

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :      Mr. Amarnath Jha
                 For the Opposite Party/s :      Mr. Nagendra Prasad
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE SANDEEP KUMAR
                                       ORAL ORDER

5   24-03-2026                  Heard the learned counsel for the petitioner and

                   learned APP for the State.

                                2. The petitioner seeks regular bail in connection with

                   Madhepura P.S. Case No. 631 of 2024 registered for the offence

                   under Sections 304B/34 of the Indian Penal Code.

                                3. As per the prosecution case, the petitioner is

                   accused of killing the deceased. Petitioner is in custody since

                   19.07.2024.

                                4. The Sessions Trial in which the petitioner is an

                   accused appears to have concluded, and the judgment may have

                   been pronounced, as is evident from the impugned report sent

                   by the court below.

                                5. In these circumstances, this application is
            Patna High Court CR. MISC. No.19034 of 2025(5) dt.24-03-2026
                                                        2/2




                      dismissed.



                                                     (Sandeep Kumar, J)
Shishir/-

U       T

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