Patna High Court
Bibi Dulari @ Gulfrana Dulari @ GulfranaversusThe State of Bihar
- Decided
- Disposal
- BAIL GRANTED
- Bench
- SANDEEP KUMAR
Holding
The court held that regular bail may be granted when the allegations are general and omnibus and the petitioner is a woman, provided she furnishes the prescribed bond and sureties.
Summary
The petitioner, Bibi Dulari, was arrested in connection with a case registered under Sections 329(4), 126(2), 115(2), 103(1), 352 and 3(5) of the B.N.S. for allegedly assaulting the deceased. She applied for regular bail, claiming innocence, a clean antecedent, and that the allegations against her were general and omnibus. The prosecution opposed the bail, arguing the seriousness of the offences. The court considered the nature of the allegations, the petitioner’s gender, and her willingness to cooperate with the trial. Finding that the allegations were not specific and taking into account the petitioner’s status as a woman, the court granted regular bail on the condition of a Rs.10,000 bond with two sureties. The order directed the lower court to release the petitioner upon furnishing the bail bond.
Issues considered
- Whether regular bail should be granted to the petitioner despite general and omnibus allegations of multiple offences
- Whether the petitioner’s gender warrants any special consideration in granting bail
Legislation cited
- B.N.S. — s. 103(1), 115(2), 126(2), 329(4), 3(5), 352
Subjects
- bail
- regular bail
- general and omnibus allegations
- gender consideration
- criminal procedure
- Bihar
Judgment
IN THE HIGH COURT OF JUDICATURE AT PATNA
CRIMINAL MISCELLANEOUS No.21134 of 2026
Arising Out of PS. Case No.-485 Year-2025 Thana- PALASI District- Araria
======================================================
Bibi Dulari @ Gulfrana Dulari @ Gulfrana W/o- Mujaffar R/v- Kujri W.No-
10, Ps- Palasi Dist- Araria
... ... Petitioner/s
Versus
The State of Bihar
... ... Opposite Party/s
======================================================
Appearance :
For the Petitioner/s : Mr.Mukesh Kumar Rana, Advocate
For the Opposite Party/s : Mr.Ajay Kumar Jha, APP
======================================================
CORAM: HONOURABLE MR. JUSTICE SANDEEP KUMAR
ORAL ORDER
2 02-04-2026 Heard learned counsel for the petitioner and learned
Additional Public Prosecutor for the State.
2. The petitioner seeks bail in connection with Palasi
P.S. Case No. 485/2025 registered for the offences punishable
under Sections 329(4), 126(2), 115(2), 103(1), 352 and 3(5) of
B.N.S.
3. As per the prosecution case, petitioner and others
are said to have assaulted the deceased.
4. Learned counsel for the petitioner submits that
petitioner is innocent and has falsely been implicated in the
present case. It is next submitted that there is general and
omnibus allegations against the petitioner. Learned counsel
further submits that petitioner has clean antecedent and she is in
custody since 29.12.2025 The petitioner undertakes to co-
Patna High Court CR. MISC. No.21134 of 2026(2) dt.02-04-2026
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operate in the case/ trial.
5. Learned APP for the State has opposed the prayer
for regular bail of the petitioner.
6. Considering the general and omnibus allegations
against the petitioner as well as the fact that petitioner is a
woman, this application for regular bail is allowed.
7. Accordingly, let the petitioner, above named, be
released on bail on furnishing bail bonds of Rs. 10,000/- (Ten
Thousand) with two sureties of the like amount each to the
satisfaction of the learned C.J.M., Araria /concerned Court
below in connection with Palasi P.S. Case No. 485/2025.
(Sandeep Kumar, J)
tusharika/-
U T
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