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Patna High Court

Vinod Ram @ Binod RamversusThe State of Bihar

Decided
Disposal
ALLOWED

Holding

The court granted anticipatory bail to the petitioners, subject to conditions under Section 482(2) of the B.N.S., 2023.

Summary

The petitioners, Vinod Ram and his wife Lalti Devi, applied for anticipatory bail fearing arrest in a dowry‑related murder case (Sahebganj P.S. Case No. 220 of 2025) filed under Sections 80, 238 and 3(5) of the B.N.S., 2023. The prosecution alleges that the deceased, Rambha Devi, was killed after being subjected to dowry cruelty, and the main accusation is against her husband, who is already in custody. The petitioners, who are the brother‑in‑law and sister‑in‑law of the deceased, contend they have no criminal antecedent and are falsely implicated. The State opposed the bail, but the court noted the allegations against the petitioners were vague and general. Accordingly, the court ordered that the petitioners be enlarged on bail, subject to surrender within four weeks, a bail bond of Rs.10,000 each and two sureties, under Section 482(2) of the B.N.S., 2023.

Issues considered

  • Whether anticipatory bail should be granted to the petitioners under Section 482(2) of the B.N.S., 2023 in view of the allegations.
  • Whether the allegations against the petitioners are specific enough to deny bail.
  • Whether the petitioners have any prior criminal record that would preclude bail.

Legislation cited

Subjects

  • anticipatory bail
  • dowry death
  • Section 482
  • bail conditions
  • criminal procedure
  • dowry cruelty

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.19483 of 2026
                   Arising Out of PS. Case No.-220 Year-2025 Thana- SAHEBGANJ District- Muzaffarpur
                 ======================================================
           1.     Vinod Ram @ Binod Ram S/O Late Sitaram Ram Village- Jagdishpur, Ward
                  No.- 04, P.s.- Sahebganj, Distt.- Muzaffarpur
           2.    Lalti Devi W/O Vinod Ram @ Binod Ram Village- Jagdishpur, Ward No.-
                 04, P.s.- Sahebganj, Distt.- Muzaffarpur

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :       Mr. Shivendra Kumar Sinha, Advocate
                                                  Mr. Ranjeet Patel, Advocate
                                                  Mr. Avnish Kumar Singh, Advocate
                 For the Opposite Party/s :       Mr. Md. Shakir Ahmad, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE ASHOK KUMAR PANDEY
                                       ORAL ORDER

2   24-04-2026                    Heard learned counsel for the petitioners and learned

                   APP for the State.

                                 2. The instant application for anticipatory bail has

                   been filed by the petitioners apprehending their arrest in

                   connection with Sahebganj P.S. Case No. 220 of 2025 instituted

                   for the offence under Sections 80, 238 and 3(5) of the B.N.S.,

                   2023.

                                 3. The case of the prosecution, in short, is that one

                   Rambha Devi was married with Dilip Ram six years ago. It is

                   alleged that she was subjected to cruelty on account of non-

                   fulfillment of dowry demand by her in-laws. On 10.05.2025, the

                   informant received an information that the deceased was ill and
Patna High Court CR. MISC. No.19483 of 2026(2) dt.24-04-2026
                                            2/3




          when he reached there, he came to know that the deceased had

          been killed.

                       4. Learned counsel appearing on behalf of the

          petitioners submits that the petitioners are innocent and have

          committed no offence and have been falsely implicated in the

          present case. It is further submitted that the nature of the

          allegations is general and omnibus. The petitioners are the

          brother-in-law and sister-in-law of the deceased. The main

          thrust of the allegations is against the husband, who is already in

          custody. He further submits that a statement has been made in

          para-3 of this petition that the petitioners have got no criminal

          antecedent.

                       5. In contra, learned APP appearing for the State has

          opposed the prayer of bail of the petitioners.

                       6. Having heard learned counsel for the parties and in

          the facts and circumstances of the case as stated above, this

          Court is inclined to enlarge the petitioners on bail. The

          petitioners are directed to surrender in the Court below within a

          period of four weeks from today and in the event of their arrest

          or surrender in connection with Sahebganj P.S. Case No. 220 of

          2025, they will be enlarged on bail on furnishing bail bond of

          Rs. 10,000/- (Rupees ten thousand) each with two sureties of the
           Patna High Court CR. MISC. No.19483 of 2026(2) dt.24-04-2026
                                                       3/3




                     like amount each to the satisfaction of learned Additional Chief

                     Judicial Magistrate-II, West Muzaffarpur subject to the

                     conditions as laid down under section 482(2) of the B.N.S.S.



                                                    (Ashok Kumar Pandey, J)
Sudhanshu/-

U      T


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