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Patna High Court

Dnyanti Devi @ Gyanti Devi @ Gayatri DeviversusThe State of Bihar

Decided
Disposal
BAIL GRANTED

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

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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