Patna High Court
Dnyanti Devi @ Gyanti Devi @ Gayatri DeviversusThe State of Bihar
- Decided
- Disposal
- BAIL GRANTED
- Bench
- RAMESH CHAND MALVIYA
Holding
The petitioner is entitled to regular bail as there is no specific allegation against her and she has no criminal antecedent.
Summary
The petitioner, Dnyanti Devi, a mother‑in‑law, was in judicial custody for a dowry‑death case (Kargahar P.S. Case No. 326 of 2025) under Sections 80(2), 103(1) read with 3(5) of the BNS, 2023. The prosecution alleged dowry death due to non‑fulfilment of dowry demand, but no specific allegation was made against the petitioner. The petitioner’s counsel argued that she was falsely implicated, had no criminal antecedent, and that the deceased’s husband was already in custody. The State opposed regular bail. The court, noting the absence of any direct charge against the petitioner, her clean record, and the fact that the primary accused was already detained, ordered her release on regular bail upon furnishing a bond of Rs. 10,000 with two sureties.
Issues considered
- Whether the petitioner, a mother‑in‑law, is entitled to regular bail in a dowry‑death case despite being in custody.
Legislation cited
- BNS, 2023 — s. 103(1), 3(5), 80(2)
Subjects
- bail
- dowry death
- mother‑in‑law
- criminal antecedent
- Section 80
- Section 103
- Section 3
- Bihar
Judgment
IN THE HIGH COURT OF JUDICATURE AT PATNA
CRIMINAL MISCELLANEOUS No.2771 of 2026
Arising Out of PS. Case No.-326 Year-2025 Thana- KARAHGAR District- Rohtas
======================================================
Dnyanti Devi @ Gyanti Devi @ Gayatri Devi W/O Ravindra Singh R/O
Village- Bakasara, P.O- Bisidihri, P.S- Karagahar,Sasaram, Dist.- Rohtas,
Bihar, Pin- 821115.
... ... Petitioner/s
Versus
The State of Bihar
... ... Opposite Party/s
======================================================
Appearance :
For the Petitioner/s : Ms. Adya Pandey, Advocate
For the Opposite Party/s : Ms. Gulnar Begum, APP
======================================================
CORAM: HONOURABLE MR. JUSTICE RAMESH CHAND
MALVIYA
ORAL ORDER
2 28-01-2026 Heard learned counsel for the petitioner and learned
APP for the State.
2. The petitioner is in custody in connection with
Kargahar P.S Case No. 326 of 2025 registered for the offences
punishable under Sections 80(2), 103(1), read with 3(5) of the
BNS, 2023.
3. As per prosecution case, it is case of dowry death
due to non-fulfillment of demand of dowry.
4. Learned counsel for the petitioner, Ms. Adya
Pandey submits that petitioner has falsely been implicated in
this case. It is further submitted that petitioner is a mother-in-
law. It is also submitted that petitioner is in judicial custody
since 12.10.2025 and petitioner has got no criminal antecedent
Patna High Court CR. MISC. No.2771 of 2026(2) dt.28-01-2026
2/2
as stated in paragraph no. 3 of the bail petition.
5. However, learned APP for the State oppose the
prayer for regular bail of the petitioner.
6. On perusal of the FIR and impugned order, it
appears that petitioner is a mother-in-law of the deceased. No
specific allegation against her. Husband of the deceased is
already in custody as submitted by the learned counsel.
Petitioner has got no criminal antecedent.
7. Considering the aforesaid facts and circumstances
of the case and submissions made on behalf of the petitioner, let
the above named petitioner 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 learned ACJM-IV,
Sasaram in connection with Kargahar P.S Case No. 326 of
2025.
(Ramesh Chand Malviya, J)
Mayank/-
U T
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