Patna High Court
Vinod SahaniversusThe State of Bihar
- Decided
- Disposal
- BAIL GRANTED
- Bench
- SANDEEP KUMAR
Holding
The court granted regular bail to the petitioners, subject to a bail bond and sureties.
Summary
The petitioners, Vinod Sahani and Gula Devi, applied for regular bail in a dowry death case (Sections 304‑B and 34 IPC) registered as Mushahari P.S. Case No. 142 of 2022. The prosecution alleged that they killed their daughter‑in‑law over dowry demands, while the petitioners claimed innocence and alleged false implication. The petitioners had been in custody since 7 October 2025 and highlighted that their son had already been granted bail in a related matter. The State opposed the bail on the basis of the serious nature of the allegations. Considering the length of custody, delay in trial, and the framing of charges on 22 December 2025, the court allowed the bail application, directing the petitioners to furnish a bail bond of Rs 10,000 with two sureties each, and clarified that the observations were prima facie and not a determination on the merits.
Issues considered
- Whether regular bail should be granted to the accused in a dowry death case under Sections 304‑B and 34 IPC given the seriousness of the allegations and the period of custody.
Legislation cited
- Indian Penal Code — s. 304-B, 34
Subjects
- regular bail
- dowry death
- IPC 304-B
- IPC 34
- criminal procedure
- bail bond
- Patna High Court
Judgment
IN THE HIGH COURT OF JUDICATURE AT PATNA
CRIMINAL MISCELLANEOUS No.32278 of 2026
Arising Out of PS. Case No.-142 Year-2022 Thana- MUSAHARI District- Muzaffarpur
======================================================
1. Vinod Sahani S/o Raghunandan Sahani R/o Vilalge - Chhoti Kathiya, P.S. -
Mushari, Dist. - Muzaffarpur.
2. Gula Devi @ Fula Devi W/o Vinod Sahani R/o Vilalge - Chhoti Kathiya,
P.S. - Mushari, Dist. - Muzaffarpur.
... ... Petitioner/s
Versus
The State of Bihar
... ... Opposite Party/s
======================================================
Appearance :
For the Petitioner/s : Mr. Ankur Agraj, Advocate
Mr. Nachiketa Jha
For the Opposite Party/s : Mr. Ganesh Prasad Singh
======================================================
CORAM: HONOURABLE MR. JUSTICE SANDEEP KUMAR
ORAL ORDER
2 19-06-2026 Heard the learned counsel for the petitioners and
learned APP for the State.
2. The petitioners seek regular bail in connection with
Mushahari (Mushari) P.S. Case No. 142 of 2022 registered for
the offence under Sections 304-B/34 of the Indian Penal Code.
3. As per the prosecution case, the petitioners are
alleged to have killed her daughter-in-law due to non-fulfillment
of dowry demand.
4. Learned counsel for the petitioners submits that
the petitioners are innocent and have falsely been implicated in
this case. He further submits that the petitioners are the father-
in-law and mother-in-law of the deceased and they are in
custody since 07.10.2025. It is further submitted that the son of
the petitioners has already been granted regular bail by this
Patna High Court CR. MISC. No.32278 of 2026(2) dt.19-06-2026
2/2
Court vide order dated 30.03.2026 in Cr. Misc. No. 77722 of
2025 and there is general and omnibus allegation against the
petitioners.
5. Learned A.P.P. for the State has vehemently
opposed the prayer for bail.
6. Considering the allegations levelled against the
petitioner, the period of custody and the delay in trial as well as
the fact that the charges have been framed on 22.12.2025, this
application for regular bail is allowed.
7. Let the petitioners, above named, 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 the learned Court below where the case is pending/successor
Court in connection with Mushahari P.S. Case No. 142 of 2022.
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 as an expression on the merits of the case
and shall not influence the trial or any other proceedings in any
manner.
(Sandeep Kumar, J)
Shishir/-
U T
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