Patna High Court

Full Devi @ Ful Devi @ Fulwati DeviversusThe State of Bihar

Decided: 10 July 2026
Disposal: DISMISSED
Bench: SANDEEP KUMAR

Holding

The Court held that regular bail could not be granted and dismissed the bail application.

Summary

The petitioner, Full Devi, mother‑in‑law of the deceased, applied for regular bail in a case registered as PS‑86 of 2020 concerning alleged murder by burning, charged under Sections 304B and 34 of the Indian Penal Code and Section 3 of the Dowry Prohibition Act. The prosecution alleges that she participated in the dowry‑related death of her daughter‑in‑law. The petitioner has been in custody since 12 February 2026. The Court examined the seriousness of the allegations, particularly the nature of dowry death offences, and considered the risk of tampering with evidence and the gravity of the crime. Concluding that the seriousness of the charge outweighs the petitioner's bail request, the Court declined to grant bail. Consequently, the bail application was dismissed.

Issues considered

Whether regular bail should be granted to the accused in a dowry death case under IPC Sections 304B and 34 and the Dowry Prohibition Act
Whether the seriousness of the alleged offence justifies denial of bail

Legislation cited

Dowry Prohibition Act — s. 3
Indian Penal Code — s. 304B, 34

Subjects

bail
dowry death
IPC 304B
Section 34
Dowry Prohibition Act
regular bail
serious offence

Judgment

                       IN THE HIGH COURT OF JUDICATURE AT PATNA
                               CRIMINAL MISCELLANEOUS No.34794 of 2026
                   Arising Out of PS. Case No.-86 Year-2020 Thana- NAYA RAM NAGAR District- Munger
                  ======================================================
                  Full Devi @ Ful Devi @ Fulwati Devi W/o Late Sipahi Paswan R/o Village-
                  Chakman Singh Indrarukh, PS- Safiasarai, Dist- Munger
                                                                             ... ... Petitioner/s
                                                   Versus
                  The State of Bihar Bihar
                                                                      ... ... Opposite Party/s
                  ======================================================
                  Appearance :
                  For the Petitioner/s     :      Mr.Arun Kumar
                  For the Opposite Party/s :      Mr.Jharkhandi Upadhyay
                  ======================================================
                  CORAM: HONOURABLE MR. JUSTICE SANDEEP KUMAR
                                        ORAL ORDER

2    10-07-2026                    Heard the parties.

                                  2. The petitioner seeks regular bail in connection with

                    Nayaram Nagar (Safiasarai) P.S. Case No. 86 of 2020 registered

                    for the offence under Sections 304(B)/34 of the Indian Penal

                    Code and under Section ¾ of the Dowry Prohibition Act.

                                 3. As per the prosecution case, the petitioner, who is

                    the mother-in-law of the deceased, is accused of killing the

                    deceased by burning her.

                                 4. The petitioner is in custody since 12.02.2026.

                                 5. Considering the seriousness of the allegation

                    levelled against the petitioner, this Court is not inclined to grant

                    bail to the petitioner.

                                 6. Accordingly, this application stands dismissed.


                                                            (Sandeep Kumar, J)
Vikas/-
U

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