Patna High Court
Juhi Praveen @ JuhiversusThe State of Bihar
- Decided
- Disposal
- BAIL GRANTED
- Bench
- ARUN KUMAR JHA
Holding
The Court held that, given the doubtful nature of the allegations and the possibility of false implication, bail should be granted to the petitioners subject to conditions.
Summary
The petitioners, Juhi Praveen, Md. Shaukat and Muskan Praveen, were implicated in a dowry harassment case (PS Case No. 361 of 2025) alleging demand of Rs. two lakh, assault and eviction of the informant, who is their daughter‑in‑law. The petitioners contended that they never demanded dowry, that the marriage was a love marriage without their consent, and that they have lived separately from the informant, filing an earlier informatory petition alleging false implication. The State and the informant maintained that the petitioners assaulted the informant and forced her out of her matrimonial home. The Court examined the doubtful and non‑specific nature of the allegations and the possibility of false implication. Relying on Section 482(2) of the CrPC, the Court ordered that the petitioners be released on bail upon furnishing a bond of Rs.10,000 with two sureties and compliance with additional conditions. The order was made subject to the petitioners appearing before the trial court as required.
Issues considered
- Whether the allegations against the petitioners constitute a false implication warranting bail.
- Whether bail can be granted under Section 482(2) of the CrPC in a dowry harassment case.
Legislation cited
- Code of Criminal Procedure, 1973 — s. 482(2)
- Dowry Prohibition Act — s. 3, 4
Subjects
- dowry harassment
- false implication
- bail
- CrPC Section 482
- domestic violence
- criminal procedure
Judgment
IN THE HIGH COURT OF JUDICATURE AT PATNA
CRIMINAL MISCELLANEOUS No.29044 of 2026
Arising Out of PS. Case No.-361 Year-2025 Thana- KHAJEKALA District- Patna
======================================================
1. Juhi Praveen @ Juhi Wife of Md. Shaukat @ Md. Shoukat @ Saukat
Resident of Mohalla- Shah Ki Imli, Mazar Ke Samne, Jinnati Masjid, Police
Station- Khajekalan, District-Patna (Bihar).
2. Md. Shaukat @ Md. Shoukat @ Saukat Son of Late Murtuja Resident of
Mohalla- Shah Ki Imli, Mazar Ke Samne, Jinnati Masjid, Police Station-
Khajekalan, District-Patna (Bihar).
3. Muskan Praveen @ Muskan Parween Daughter of Md. Shaukat @ Md.
Shoukat @ Saukat Resident of Mohalla- Shah Ki Imli, Mazar Ke Samne,
Jinnati Masjid, Police Station- Khajekalan, District-Patna (Bihar).
... ... Petitioner/s
Versus
The State of Bihar
... ... Opposite Party/s
======================================================
Appearance :
For the Petitioner/s : Mr.Akash Kumar Mishra, Advocate
Mr. Parijat Karan, Advocate
For the State : Mr.Surendra Prasad Singh, APP
For the Informant : Ms. Shifa Khan, Advocate
Ms. Shivani Roy, Advocate
Mr. Manas Raj, Advocate
======================================================
CORAM: HONOURABLE MR. JUSTICE ARUN KUMAR JHA
ORAL ORDER
2 06-05-2026 Heard learned counsel for the petitioners and learned
APP for the State as well as learned counsel appearing on behalf
of the informant.
2. In the present case, the petitioners are
apprehending their arrest in connection with Khajekalan P.S.
Case No. 361 of 2025 registered for the offences under Sections
85, 115(2), 351(2), 352, 3(5) of BNS and Section 3/4 of Dowry
Prohibition Act.
Patna High Court CR. MISC. No.29044 of 2026(2) dt.06-05-2026
2/4
3. As per prosecution case, the informant was
married with co-accused Md. Rafique and the petitioners are
parents-in-law and sister-in-law of the informant. The allegation
against the petitioners and other co-accused persons is that they
used to demand Rs.Two lakhs as dowry and on non-fulfillment
of the demand, they used to assault the informant and drove her
out from their house.
4. Learned counsel for the petitioners submits that
the petitioners are innocent and have falsely been implicated in
this case. The petitioners have not demanded any dowry and
never tortured the informant and the son of petitioner nos. 1 and
2 was a love marriage without the consent and approval of the
petitioners and the petitioners have been living separately from
the informant and her husband since the very beginning of their
matrimonial life. Since they have been residing separately, there
was no question of day-to-day interference or committing
cruelty by the petitioners. Much before the institution of the
present FIR, petitioner no. 1 has already filed informatory
petition before the learned ACJM-I, Patna City bearing
Informatory Petition No. 2304 of 2025 apprehending false
implication. Learned counsel further submits that, moreover, the
allegations are non-specific, general and omnibus. The
Patna High Court CR. MISC. No.29044 of 2026(2) dt.06-05-2026
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petitioners are having clean antecedent.
5. Learned APP as well as learned counsel appearing
on behalf of the informant vehemently oppose the submission
made on behalf of the petitioners. Learned counsel for the
informant submits that the informant lived peacefully for
sometime in her matrimonial home and thereafter, driven out
from her matrimonial home and the petitioners assaulted the
informant in her rented house and thereafter, the husband of the
informant absconded leaving her behind.
6. Having regard to the facts and circumstances and
submissions made on behalf of the parties and considering the
completely doubtful nature of allegation against the petitioners
and possibility of false implication, let the petitioners above
named, in the event of their arrest or surrender before the court
concerned within a period of eight weeks from today, be
released on bail, on furnishing bail bonds of Rs.10,000/-
(Rupees Ten Thousand Only) each with two sureties of the like
amount each to the satisfaction of learned Judicial Magistrate,
Ist Class, Patna City/concerned court in connection with
Khajekalan P.S. Case No. 361 of 2025, subject to the condition
as laid down under Section 482(2) of the B.N.S.S. and other
following conditions :
Patna High Court CR. MISC. No.29044 of 2026(2) dt.06-05-2026
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(i) One of the bailors will be a close
relative of the petitioners.
(ii) The petitioners will remain present
on each and every date fixed by the
court below, if so required by the
learned trial court.
(Arun Kumar Jha, J)
DKS/-
U T
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