Patna High Court
Anjani DeviversusThe State of Bihar
- Decided
- Disposal
- BAIL GRANTED
- Bench
- ANSUL
Holding
Bail was granted to the petitioner on the condition of a Rs 10,000 bond with two sureties.
Summary
Anjani Devi, the mother‑in‑law of a woman who was allegedly killed in a dowry dispute, was arrested in connection with offences under Section 80 of the Bhartiya Nagarik Suraksha Sanhita (BNS) and Sections 3 and 4 of the Dowry Prohibition Act. She applied for bail, contending that the primary accusation is against the husband, that she has no prior criminal record, and that she has been in custody since 25‑12‑2025. The State opposed the bail. The Court, noting her lack of antecedents and her relationship to the deceased, granted bail on a bond of Rs 10,000 with two sureties, subject to the conditions of Section 438(2) of the CrPC and Section 482(2) of the BNS. The order is expressly limited to the bail application and does not prejudice the merits of the trial.
Issues considered
- Whether bail should be granted to the petitioner under Section 438(2) CrPC/Section 482(2) BNS in a case involving alleged dowry death offences.
Legislation cited
- Bhartiya Nagarik Suraksha Sanhita — s. 482(2), 80
- Code of Criminal Procedure — s. 438(2)
- Dowry Prohibition Act — s. 3, 4
Subjects
- bail
- dowry death
- Bhartiya Nagarik Suraksha Sanhita
- Dowry Prohibition Act
- Criminal Procedure Code
- mother‑in‑law
- no antecedent
Judgment
IN THE HIGH COURT OF JUDICATURE AT PATNA
CRIMINAL MISCELLANEOUS No.30095 of 2026
Arising out of PS. Case No.-346 Year-2025 Thana- NADI P.S. District- Patna
======================================================
Anjani Devi W/o Madan Ray Resident of village - Maujipur, P.S.- Fatuha,
Maujipur, District - Patna, Bihar
... ... Petitioner/s
Versus
The State of Bihar
... ... Opposite Party/s
======================================================
Appearance :
For the Petitioner/s : Mr. Ashutosh Nath, Advocate
For the Opposite Party/s : Mr. Jagdhar Prasad, APP
For the Informant : Mr. Shyamol Prakash, Advocate
Mr. Sitesh Kashyap, Advocate
Mr. Raushan Raj, Advocate
======================================================
CORAM: HONOURABLE MR. JUSTICE ANSUL
ORAL ORDER
2 06-05-2026 Heard learned counsel for the petitioner and learned
Additional Public Prosecutor for the State.
2. The petitioner seeks bail in Nadi P.S. Case No. 346
of 2025 registered for the offences punishable under Sections 80
of BNS and 3/4 of DP Act.
3. The allegation is that the informant married his
sister to one Aakash Kumar and after two months of the
marriage the family members of the in-laws’ house started
demanding dowry and on non-fulfilment of the same they killed
her sister.
4. Learned counsel for the petitioner submits that crux
of the allegation is against the husband who is in custody. He
further submits that the petitioner is the mother-in-law of the
Patna High Court CR. MISC. No.30095 of 2026(2) dt.06-05-2026
2/3
deceased and she is in custody since 25.12.2025 and has no
criminal antecedent.
5. Learned Additional Public Prosecutor for the State
has vehemently opposed the prayer for bail of the petitioner.
6. Considering that the petitioner is the mother-in-law
of the deceased and is in custody since 25.12.2025 having no
criminal antecedent, this Court is inclined to grant bail to the
petitioner.
7. Let the petitioner, above named, be
released on bail on furnishing bail bond of Rs.
10,000/- (Ten thousand) with two sureties of the like
amount each to the satisfaction of the learned learned
Judicial Magistrate, 1 s t Class/Concerned Court, Patna
City, Patna in connection with Nadi P.S. Case No. 346
of 2025, subject to the conditions as laid down under
Section 438(2) of the Code of Criminal Procedure /
Section 482(2) of the Bhartiya Nagarik Suraksha
Sanhita.
8. It is made clear that any observation made
herein is prima facie in nature and limited solely for
the purpose of adjudication of the present bail
application. Such observations shall not be construed
Patna High Court CR. MISC. No.30095 of 2026(2) dt.06-05-2026
3/3
as an expression on the merits of the case and shall not
influence the trial or any other proceedings in any
manner.
(Ansul, J)
Vikash/-
U T
Checking your session…
Lawyer court records for this case
Associated through the court’s case reference.