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Patna High Court

Nandlal SinghversusThe State of Bihar

Decided
Disposal
PARTLY ALLOWED (DISPOSAL)

Holding

Petitioners 1, 3 and 4 are entitled to anticipatory bail, while petitioner 2 is denied bail.

Summary

The petitioners – the father‑in‑law, mother‑in‑law and two brothers‑in‑law of a missing woman – applied for anticipatory bail in a dowry‑related case (Section 80, 3(5) of BNS) after the woman disappeared following a dowry demand. The FIR alleged that the petitioners conspired to make the woman disappear, but the petitioners contended that the allegations were vague, they were falsely implicated, and the victim had left her matrimonial home voluntarily. The court examined the FIR, case diary and material evidence, noting that no specific role was attributed to the father‑in‑law and brothers‑in‑law, whereas the mother‑in‑law’s proximity to the household raised suspicion. Consequently, the court granted anticipatory bail to petitioners 1, 3 and 4 subject to a bail bond of Rs 10,000 with two sureties and verification of criminal antecedents, but denied bail to petitioner 2. The order was conditioned on Section 482(2) of the B.N.S.S. and the application was disposed of.

Issues considered

  • Whether the father‑in‑law and brothers‑in‑law are entitled to anticipatory bail under Section 80 of the CrPC/BNS in the dowry‑death case.
  • Whether the mother‑in‑law should be denied anticipatory bail due to her close proximity to the matrimonial household.
  • Whether Section 482(2) of the B.N.S.S. can be invoked to impose conditions on the grant of anticipatory bail.

Legislation cited

Subjects

  • anticipatory bail
  • dowry death
  • missing person
  • family members
  • Section 80
  • Section 482
  • Bihar
  • bail conditions

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.21301 of 2026
                      Arising Out of PS. Case No.-437 Year-2025 Thana- JANDAHA District- Vaishali
                 ======================================================
           1.     Nandlal Singh Son of Late Mahadev Singh Resident of Village - Rampur,
                  Bhanborhan, P.S.- Jandaha, District - Vaishali
           2.    Shanti Devi Wife of Nandlal Singh Resident of Village - Rampur,
                 Bhanborhan, P.S.- Jandaha, District - Vaishali
           3.    Dharmendra Singh @ Dharmendra Kumar Son of Nandlal Singh Resident of
                 Village - Rampur, Bhanborhan, P.S.- Jandaha, District - Vaishali
           4.    Bilendra Singh @ Birendra Kumar Singh @ Virendra Kumar Singh Son of
                 Nandlal Singh Resident of Village - Rampur, Bhanborhan, P.S.- Jandaha,
                 District - Vaishali
                                                                         ... ... Petitioner/s
                                                   Versus
          1.     The State of Bihar
          2.     Vinod Kumar Singh, S/o Late Ram Ashish Singh, R/o-Village-Vishanpur,
                 P.S.- Garoul, District- Vaishali.

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :       Mr.Pranav Kumar Jha, Advocate
                 For the Opposite Party/s :       Mr.Anand Kishore Choudhary, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE PURNENDU SINGH
                                       ORAL ORDER

2   16-04-2026                          Heard Mr. Pranav Kumar Jha, learned counsel

                   appearing on behalf of the petitioners and Mr. Anand Kishore

                   Choudhary, learned APP for the State.

                                2. The petitioners seek pre-arrest bail in connection

                   with Jandaha P.S. Case No. 437/2025 registered for the offence

                   punishable under Section 80, 3(5) of BNS.

                                  3. As per the allegation made in the FIR, after the

                   marriage of the informant’s daughter with one Ranveer Singh,

                   she was allegedly subjected to a dowry demand of Rs. 5 lakh,

                   and thereafter, she went missing from her matrimonial home,
Patna High Court CR. MISC. No.21301 of 2026(2) dt.16-04-2026
                                            2/4




          leading the informant to suspect that the petitioners have

          conspired to make her disappear or have killed her.

                       4. Learned counsel appearing on behalf of the

          petitioners submits that the petitioners are innocent and have

          been falsely implicated in the present case. The petitioners,

          being in-laws of the victim, were residing separately and there is

          no specific allegation against them, the allegations being general

          and omnibus in nature. The Petitioner No.1 is the Father-in-Law

          (Sasur), Petitioner No.2 is the Mother-in-Law (Saas), Petitioner

          No.3 and 4 are Brother-In-Law (Bhaisur) of the Victim girl.

          Learned counsel contends that, as per the materials collected

          during investigation and the case diary, the victim had left on

          her own and is still untraceable, and even otherwise, the specific

          allegations, if any, are against the husband. On these grounds,

          the petitioners seek to be released on pre-arrest bail.

                       5. Learned APP for the State vehemently opposed the

          prayer for grant of pre-arrest bail.

                       6. Having heard the rival submissions made on behalf

          of the parties, as well as, having considered the allegations made

          in the FIR and the materials available on record, it appears that

          petitioner no.1 is the father-in-law (sasur), petitioner no.2 is the

          mother-in-law (saas), and petitioner nos.3 and 4 are the
Patna High Court CR. MISC. No.21301 of 2026(2) dt.16-04-2026
                                            3/4




          brothers-in-law (bhaisur) of the victim. From the case diary, it

          also appears that the victim had left her matrimonial home on

          her own and is still untraceable. Considering the aforesaid facts

          and the nature of allegations, I am of the opinion that petitioner

          no. 1 (father-in-law) and petitioner nos. 3 and 4 (brothers-in-

          law), against whom no specific role has been attributed, have,

          prima facie, made out a case to be released on anticipatory bail.

                       7. The learned District Court is directed to release the

          petitioner nos.1, 3 and 4 on anticipatory bail, in the event of

          their arrest or surrender before the learned District Court within

          a period of four weeks from today, on furnishing bail bond of

          Rs. 10,000/- (Ten thousand) with two sureties of the like amount

          each, to the satisfaction of learned District Court where the case

          is pending in connection with Jandaha P.S. Case No. 437/2025,

          subject to the condition as laid down under Section 482(2) of

          the B.N.S.S.

                       8. The learned District Court is directed to verify

          the criminal antecedent of the petitioners, as stated in

          paragraph no. 3 of the bail application. If any other case is

          pending against the petitioners, as what has been stated in

          paragraph no. 3, this order will lose its force automatically.

                       9. However, so far as petitioner no. 2, the mother-
           Patna High Court CR. MISC. No.21301 of 2026(2) dt.16-04-2026
                                                       4/4




                     in-law of the victim, is concerned, considering her close

                     proximity in the matrimonial household and the possibility

                     of her involvement, I am not inclined to grant her the

                     privilege of anticipatory bail at this stage.

                                  10. Accordingly, the present application stands

                     disposed of.



                                               (Purnendu Singh, J)
Ashishsingh/-

U      T


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