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Patna High Court

Ranjan KumarversusThe State of Bihar

Decided
Disposal
BAIL REJECTED

Holding

The court held that bail could not be granted as the petitioner, being the husband of the deceased who died under suspicious circumstances, is a flight risk and the nature of the offence warrants continued custody.

Summary

Petitioner Ranjan Kumar applied for regular bail in a dowry death case registered under Sections 80(2) and 3(5) of the Bharatiya Nyaya Sanhita. The prosecution alleges that the petitioner, as husband, participated in the killing of his wife over dowry demands. The petitioner contended he did not demand dowry, did not torture the deceased, and that she committed suicide, asserting a clean antecedent and custody since 24‑07‑2025. The State opposed bail, citing the post‑mortem report indicating asphyxia due to pressure on the neck. The court, considering the serious nature of the accusation, the petitioner’s relationship to the deceased, and the unnatural circumstances of death, rejected the bail application and directed the trial court to expedite the trial within a year.

Issues considered

  • Whether the petitioner is entitled to regular bail under Sections 80(2) and 3(5) of the Bharatiya Nyaya Sanhita in a dowry death case.
  • Whether the nature of the accusation and the circumstances of the deceased's death justify denial of bail.

Legislation cited

Subjects

  • regular bail
  • dowry death
  • Bharatiya Nyaya Sanhita
  • criminal procedure
  • murder
  • husband-wife relationship
  • post‑mortem report

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.19223 of 2026
                   Arising Out of PS. Case No.-112 Year-2025 Thana- PARASBIGHA District- Jehanabad
                 ======================================================
                 Ranjan Kumar S/o Vinod Yadav R/o Vill- Shahpur, P.s.- Parasbigha, Distt-
                 Jehanabad, Bihar

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :      Mr. Anmol Kumar, Advocate
                 For the Opposite Party/s :      Mr. Rajendra Nath Jha, A.P.P.
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE PRABHAT KUMAR SINGH
                                       ORAL ORDER

2   01-05-2026                  Heard learned counsel for the petitioner and learned

                   A.P.P. for the State.

                                2. Petitioner seeks regular bail in connection with

                   Parasbigha P. S. Case No. 112 of 2025 registered for the offence

                   punishable under Sections 80(2), 3(5) of the Bharatiya Nyaya

                   Sanhita.

                                3. Prosecution case, in brief, is that marriage of the

                   daughter of informant was solemnized with this petitioner in the

                   year 2022 and thereafter it is alleged that all the F.I.R. named

                   accused persons including this petitioner killed the daughter of

                   informant due to non-fulfillment of demand of dowry.

                                4. Learned counsel for the petitioner submits that

                   petitioner is innocent and has committed no offence. Petitioner

                   never demanded any dowry nor tortured the deceased. As a
              Patna High Court CR. MISC. No.19223 of 2026(2) dt.01-05-2026
                                                          2/2




                        matter of fact, deceased herself committed suicide. Petitioner

                        claims clean antecedent and is in custody since 24.07.2025.

                                     5. Learned A.P.P. for the State vehemently opposed

                        the bail application and submitted that as per post-mortem

                        report, cause of death is Asphyxia due to pressure on neck.

                                     6. Considering the nature of accusation and the fact

                        that petitioner is husband of the deceased who died in her

                        matrimonial house within seven years of marriage, under

                        unnatural circumstances, prayer for bail of the petitioner is

                        rejected.

                                     7. However, since petitioner is in custody since

                        24.07.2025, Trial Court is directed to expedite and conclude the

                        trial, preferably, within a period of one year from the date of

                        receipt/production of copy of this order.



                                              (Prabhat Kumar Singh, J)
Navya/-

U         T


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