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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

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
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           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


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