Patna High Court
Satrudhan Kumar @ Satrudhan SahaniversusThe State of Bihar
- Decided
- Disposal
- BAIL GRANTED
- Bench
- PARTHA SARTHY
Holding
The court granted anticipatory bail to the petitioner, subject to a bail bond of Rs 10,000 and two sureties.
Summary
The petitioner, Satrudhan Kumar, applied for anticipatory bail fearing arrest in Mahila Police Station Case No.27 of 2024, which alleged dowry demand, torture, and assault under several sections of the Bharatiya Nyaya Sanhita, 2023 and the Dowry Prohibition Act, 1961. The prosecution’s informant claimed the petitioner’s in‑laws demanded Rs 7 lakh as dowry and subjected her to abuse, leading to her rescue by police on 6‑July‑2024. The petitioner contended that the allegations were fabricated, citing a prior false case (Madhuban PS Case No.619 of 2023) for which he had already been granted anticipatory bail. The State opposed the bail, but the court, after considering the FIR allegations, the earlier bail order, and the marital relationship, directed that the petitioner be released on anticipatory bail upon furnishing a bail bond of Rs 10,000 with two sureties. The order was made subject to compliance with the conditions set by the Sub‑Divisional Judicial Magistrate, Sadar, Motihari.
Issues considered
- Whether anticipatory bail should be granted to the petitioner in view of the alleged offences under the Bharatiya Nyaya Sanhita and the Dowry Prohibition Act.
Legislation cited
- Bharatiya Nyaya Sanhita, 2023 — s. 115(2), 126, 3(5), 351(2), 61(2), 82, 85
- Dowry Prohibition Act, 1961 — s. 3, 4
Subjects
- anticipatory bail
- dowry harassment
- Bharatiya Nyaya Sanhita
- Dowry Prohibition Act
- false allegations
- bail bond
Judgment
IN THE HIGH COURT OF JUDICATURE AT PATNA
CRIMINAL MISCELLANEOUS No.3382 of 2026
Arising Out of PS. Case No.-27 Year-2024 Thana- MAHILA PS District- East Champaran
======================================================
Satrudhan Kumar @ Satrudhan Sahani S/O Nathuni Sahani R/O Village-
Chauhaniya, Ward No. 9, P.S.- Madhuban, District- East Champaran
... ... Petitioner/s
Versus
1. The State of Bihar
2. Rambha Kumari W/O Satrudhan Kumar @ Satrudhan Sahani R/O Village-
Chauhaniya, P.S.- Madhuban, District- East Champaran
... ... Opposite Party/s
======================================================
Appearance :
For the Petitioner : Mr. Anil Kumar, Advocate
Mr. Shamir Mehra, Advocate
Mr. Rajeev Ranjan Ray, Advocate
For the State : Mr. Aditya Narayan Singh.1, APP
For the O.P. No.2 : None
======================================================
CORAM: HONOURABLE MR. JUSTICE PARTHA SARTHY
ORAL ORDER
4 22-04-2026 Heard learned counsel for the petitioner and learned
A.P.P. for the State. No one appears on behalf of the opposite
party no.2.
2. The petitioner has preferred this application for
grant of anticipatory bail apprehending his arrest in connection
with Mahila P.S. Case no.27 of 2024, registered under sections
61(2), 82, 85, 115(2), 126, 351(2) and 3(5) of the Bharatiya
Nyaya Sanhita, 2023 and sections 3 and 4 of the Dowry
Prohibition Act, 1961.
3. As per the prosecution case, the informant states
that she was married to the petitioner and that her father had
Patna High Court CR. MISC. No.3382 of 2026(4) dt.22-04-2026
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given Rs.7 lacs by way of gifts etc. However the accused
persons including the petitioner herein started to torture her for
non-fulfillment of the demand of dowry. She was abused and
assaulted. She was taken to an unknown spot by her in-laws
from where she was recovered by the police on 6.7.2024.
4. Learned counsel for the petitioner submits that the
petitioner has been falsely implicated in the case. The
allegations with respect to demand of dowry and torture etc. are
all false and concocted. Even on an earlier occasion, a false case
being Madhuban P.S. Case no.619 of 2023 was lodged by the
informant, however the petitioner was enlarged on anticipatory
bail vide order dated 26.6.2024 passed in Cr. Misc. no.36918 of
2024. The petitioner undertakes to cooperate in the
investigation/trial.
5. The application for anticipatory bail is opposed by
learned A.P.P. for the State.
6. Having heard learned counsel for the parties and
taking into consideration the allegation against the petitioner in
the F.I.R., the contents of the earlier F.I.R. wherein the petitioner
was granted anticipatory bail vide order dated 26.6.2024 and the
relationship between the parties, it is directed that the petitioner,
above named, in the event of his arrest or surrender before the
Patna High Court CR. MISC. No.3382 of 2026(4) dt.22-04-2026
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learned Court below within a period of four weeks, be released
on anticipatory bail in connection with Mahila P.S. Case no.27
of 2024 on furnishing bail bond of Rs.10,000/- (Rupees Ten
Thousand) with two sureties of the like amount each to the
satisfaction of the learned Sub Divisional Judicial Magistrate,
Sadar, Motihari, East Champaran.
(Partha Sarthy, J)
avinash/-
U T
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