Patna High Court

Ram Nandan Mahto @ RamanandversusThe State of Bihar

Decided: 29 January 2026
Disposal: ALLOWED
Bench: ASHOK KUMAR PANDEY

Holding

The court granted regular bail to the petitioner.

Summary

The petitioner, Ram Nandan Mahto, sought regular bail in a criminal case registered under sections 85 and 80(2) of the B.N.S. Act and sections 3 and 4 of the Dowry Prohibition Act, relating to the dowry‑related death of his daughter‑in‑law, Neha Kumari. The prosecution alleged that the deceased was subjected to cruelty for non‑payment of dowry and was eventually killed on 18‑08‑2025, with the husband already in judicial custody. The petitioner contended that he is innocent, has no criminal antecedent, and that the main allegation is against the husband, not him; he also highlighted that the case was originally filed under Section 80(2) and later converted to Section 103 of the B.N.S. Act. The State opposed the bail application, arguing the seriousness of the offences. After hearing both sides, the court found no material reason to deny bail and ordered the petitioner’s release on a bail bond of Rs.10,000 with two sureties. The bail order was directed to be complied with before the Chief Judicial Magistrate, Begusarai.

Issues considered

Whether the petitioner is entitled to regular bail despite being charged under sections 85 and 80(2) of the B.N.S. Act and sections 3 and 4 of the Dowry Prohibition Act
Whether the nature of the allegations and the petitioner’s lack of criminal antecedent justify granting bail

Legislation cited

B.N.S. — s. 103, 80(2), 85
Dowry Prohibition Act — s. 3, 4

Subjects

regular bail
dowry death
criminal procedure
B.N.S. Act
Dowry Prohibition Act
father‑in‑law
criminal antecedent

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.3022 of 2026
                 Arising Out of PS. Case No.-339 Year-2025 Thana- BEGUSARAI TOWN District- Begusarai
                 ======================================================
                 Ram Nandan Mahto @ Ramanand S/o Yogeshwar Mahto R/O- Hawaspur,
                 P.S.- Mansurchak, Distt- Begusarai
                                                                   ... ... Petitioner/s
                                                    Versus
                 The State of Bihar
                                                            ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :      Mr. Ram Jiban Pd. Singh, Advocate
                 For the Opposite Party/s :      Mr. Surendra Prasad Singh, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE ASHOK KUMAR PANDEY
                                       ORAL ORDER

2   29-01-2026                     Heard learned counsel for the petitioner and learned

                   APP for the State.

                                2. The petitioner has prayed for regular bail in a case

                   registered for the offence punishable under sections 85 and 80(2)

                   of B.N.S. and Section 3 and 4 of Dowry Prohibition Act.

                                3. The case of the prosecution is that Neha Kumari

                   (deceased) was married to one Niraj Kumar. At the time of

                   marriage, sufficient gifts were given. It is alleged that she was

                   subjected to cruelty on account of non-fulfillment of dowry

                   demand. Later on, Rs. 1,50,000/- was also given to the husband

                   of the deceased. Ultimately, she was killed on 18.08.2025.

                                4. Learned counsel for the petitioner submits that the

                   petitioner is innocent and has committed no offence. Learned

                   counsel for the petitioner has submitted that earlier the case was

                   filed under Section 80(2) of B.N.S.S. however, as the marriage
            Patna High Court CR. MISC. No.3022 of 2026(2) dt.29-01-2026
                                                        2/2




                      was solemnized before more than seven years, ultimately, the

                      case was converted 103 of the B.N.S. Learned counsel for the

                      petitioner has further submitted that the petitioner is father-in-law

                      of the deceased and the nature of allegation is general and

                      omnibus. The main thrust of allegation is against the husband of

                      the deceased who is already in judicial custody. A statement has

                      been made in para-3 of this petition that the petitioner has got no

                      criminal antecedent. Moreover, he is languishing in judicial

                      custody since 11.10.2025.

                                   5. Learned APP appearing for the State has vehemently

                      opposed the prayer of regular bail.

                                   6. Having heard learned counsel for the parties and

                      considering the facts and circumstances of the case, this court is

                      inclined to enlarge the petitioner on bail. The above named

                      petitioner is directed to be released on bail in connection with

                      Begusarai Town P.S. Case No. 339 of 2025 on furnishing bail

                      bond of Rs.10,000/- (ten thousand) with two sureties of the like

                      amount each to the satisfaction of learned C.J.M., Begusarai.



                                             (Ashok Kumar Pandey, J)
Shubham/-
U     T

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