Patna High Court
Rajeev Kumar Singh @ Rajeev Kumar RanjanversusThe State of Bihar
- Decided
- Disposal
- BAIL GRANTED
- Bench
- ANIL KUMAR SINHA
Holding
The court granted anticipatory bail to all petitioners, finding the allegations against them to be general and the charge‑sheet to be directed mainly at the husband.
Summary
The petitioners, who are relatives of the deceased woman's husband, were implicated in a dowry‑death case (Police Station Case No. 652 of 2025) alleging they demanded a Rs.5 lakh dowry and caused the victim's death by poison. They contended that the allegations against them were vague, general and omnibus, and that only the husband had been formally charged under Section 108 of the Bhartiya Nyaya Sanhita. The court examined the submissions and noted that the charge‑sheet targeted the husband, while the petitioners were merely named on the basis of unsubstantiated accusations. Considering their familial relationship to the husband and the lack of specific material against them, the court exercised its power under Section 482(2) of the Bhartiya Nagrik Suraksha Sanhita to grant anticipatory bail. The petitioners were ordered to furnish bail bonds of Rs.10,000 each with two sureties if arrested within four weeks.
Issues considered
- Whether the petitioners are entitled to anticipatory bail despite being named in the dowry‑death FIR under Sections 103(1) and 3(5) of the Bhartiya Nyaya Sanhita.
- Whether the allegations against the petitioners are sufficiently specific to deny bail, given that the charge‑sheet primarily targets the deceased's husband under Section 108.
Legislation cited
- Bhartiya Nagrik Suraksha Sanhita — s. 482(2)
- Bhartiya Nyaya Sanhita — s. 103(1), 108, 3(5)
Subjects
- anticipatory bail
- dowry death
- false implication
- charge sheet
- Section 103
- Section 108
- Section 482
- Bhartiya Nyaya Sanhita
- Bhartiya Nagrik Suraksha Sanhita
- criminal procedure
Judgment
IN THE HIGH COURT OF JUDICATURE AT PATNA
CRIMINAL MISCELLANEOUS No.29388 of 2026
Arising Out of PS. Case No.-652 Year-2025 Thana- VAISHALI District- Vaishali
======================================================
1. Rajeev Kumar Singh @ Rajeev Kumar Ranjan S/O Deepnarayan Singh R/O
Vill-Dumdumma, P.S.-Vaishali, District-Vaishali.
2. Munni Kumari @ Munni Devi D/O Deepnarayan Singh R/O Vill-
Dumdumma, P.S.-Vaishali, District-Vaishali.
3. Punam Devi D/O Deepnarayan Singh R/O Vill-Dumdumma, P.S.-Vaishali,
District-Vaishali.
4. Sanjay Singh S/O Kishun Singh R/O Village- Rambhadra, P.S- Hajipur
Town, Dist.- Vaishali.
... ... Petitioner/s
Versus
The State of Bihar
... ... Opposite Party/s
======================================================
Appearance :
For the Petitioner/s : Mr. Ayushi Gupta
For the Opposite Party/s : Mr. Tarun Prasad Mandal
======================================================
CORAM: HONOURABLE MR. JUSTICE ANIL KUMAR SINHA
ORAL ORDER
2 07-05-2026 1. Heard learned counsel for the petitioner and learned
Additional Public Prosecutor for the State.
2. This application, for grant of anticipatory bail, arises out
of Vaishali Police Station Case No. 652 of 2025, dated
12.09.2025, disclosing offences under Sections
103(1)/3(5) of the Bhartiya Nyaya Sanhita.
3. The prosecution case, as per the First Information Report,
is that the marriage of the informant’s daughter was
solemnized with co-accused Mithun Kumar on
07.07.2014. It has further been alleged that the
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petitioners, along with other accused persons, after some
time of the marriage, started demanding a sum of Rs. 5
lakhs as dowry and due to non-fulfillment of the said
demand, they subjected the informant’s daughter to
cruelty and ultimately killed her by administering poison.
4. Learned counsel for the petitioners submits that the
petitioners have falsely been implicated in present case
without any cogent material. The marriage was
solemnized about 10 years back and entire family
members, including the petitioners, of deceased’s husband
have been made accused on the basis of general and
omnibus allegations. He next submits that the petitioner
no. 1 is the brother-in-law of the deceased, petitioner nos.
2 and 3 are Nanads (sister-in-law) and petitioner no. 4 is
Nandosi (brother-in-law). He further submits that the
husband of the deceased is in custody and the police, after
investigation, has submitted charge-sheet under Sections
108/3(5) of the Bhartiya Nyaya Sanhita.
5. Having regard to the submissions made on behalf of the
parties and taking into consideration the fact that the
petitioners are relatives of deceased’s husband, the
allegations against the petitioners are general and
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omnibus in nature and the police, after investigation, has
submitted charge-sheet under Section 108 of the Bhartiya
Nyaya Sanhita and allied sections therein against the
deceased’s husband, I am inclined to grant privilege of
anticipatory bail to the petitioners.
6. This application is, accordingly, allowed.
7. Let the petitioners, above named, in the event of their
arrest or surrender before the Court below within four
weeks, be released on bail on furnishing bail bond of Rs.
10,000/- (Ten Thousand) each with two sureties of the
like amount each to the satisfaction of learned Judicial
Magistrate First Class, Vaishali at Hajipur, in connection
with Vaishali Police Station Case No. 652 of 2025,
subject to the condition laid down under Section 482 (2)
of the Bhartiya Nagrik Suraksha Sanhita, 2023.
(Anil Kumar Sinha, J)
ashwani/-
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