Patna High Court
Ram Nath SahaniversusThe State of Bihar
- Decided
- Disposal
- BAIL GRANTED
- Bench
- SANDEEP KUMAR
Holding
Anticipatory bail was granted to the petitioner subject to conditions under Section 482 of the BNSS.
Summary
The petitioner, a 76‑year‑old father‑in‑law, applied for anticipatory bail in a dowry‑death case (PS No.603/2025) where he was alleged to have participated in the killing of his daughter‑in‑law. The prosecution alleged the death was a homicide motivated by dowry demands, while the defence argued the deceased had hanged herself after an altercation and that there were no external injuries except a ligature mark. The court considered the petitioner’s advanced age, the circumstances of the investigation, and the lack of incriminating physical evidence. It held that these factors warranted the grant of anticipatory bail, subject to standard conditions under Section 482 of the Bharatiya Nagarik Suraksha Sanhita. The order clarified that the bail decision does not prejudice the merits of the trial, which will proceed independently.
Issues considered
- Whether anticipatory bail should be granted to the petitioner in a dowry‑death case.
- Whether the petitioner’s age and the evidentiary circumstances justify the grant of bail.
- Whether conditions under Section 482 of the Bharatiya Nagarik Suraksha Sanhita can be imposed on anticipatory bail.
Legislation cited
- Bharatiya Nagarik Suraksha Sanhita — s. 103(1), 3(5), 482, 80(2), 85
Subjects
- anticipatory bail
- dowry death
- senior citizen
- bail conditions
- criminal procedure
Judgment
IN THE HIGH COURT OF JUDICATURE AT PATNA
CRIMINAL MISCELLANEOUS No.35047 of 2026
Arising Out of PS. Case No.-603 Year-2025 Thana- HARSIDHI District- East Champaran
======================================================
Ram Nath Sahani S/o Late Ramawatar Sahani Resident of Village- Kubra,
P.S.- Harsiddhi, District- East Champaran
... ... Petitioner/s
Versus
The State of Bihar
... ... Opposite Party/s
======================================================
Appearance :
For the Petitioner/s : Mr. Patanjali Rishi, Advocate
For the Opposite Party/s : Mr. Shyam Kumar Singh, APP
Mr. Shyameshwar Dayal
======================================================
CORAM: HONOURABLE MR. JUSTICE SANDEEP KUMAR
ORAL ORDER
2 10-07-2026 Heard learned counsel for the petitioner and learned
APP for the State.
2. The petitioner seeks anticipatory bail in connection
with Harsidhi P.S. Case No. 603 of 2025 registered for the
offence under Sections 85, 80(2), 3(5) of the BNS and Section
103(1) which was added later.
3. As per the prosecution case, the petitioner and
others are said to have killed the deceased for demand of dowry.
4. Learned counsel for the petitioner submits that the
petitioner is a 76-year-old man and the father-in-law of the
deceased. It is further submitted that the deceased had an
altercation with her husband over a mobile phone, following
which she allegedly committed suicide by hanging herself.
Patna High Court CR. MISC. No.35047 of 2026(2) dt.10-07-2026
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Learned counsel further contends that, apart from the ligature
mark on the neck, no other external injury was found on the
body of the deceased.
5. Learned APP for the State has vehemently opposed
the prayer for anticipatory bail.
6. Considering the aforesaid facts and circumstances
of the case, the age of the petitioner and the materials collected
during investigation, this application for anticipatory bail is
allowed.
7. Let the petitioner, above named, in the event of
arrest or surrender before the Court below within a period of
four weeks from today, be released on anticipatory bail on
furnishing bail bond of Rs. 10,000/- (Ten Thousand) with two
sureties of the like amount each to the satisfaction of the
concerned Court below in connection with Harsidhi P.S. Case
No. 603 of 2025, subject to the conditions as laid down under
Section 482 of the Bharatiya Nagarik Suraksha Sanhita (BNSS)
and with further conditions that:-
(I). The petitioner shall co-operate with
the investigation and shall appear in the trial
either by appearing personally or through his
lawyer in the trial Court on each and every date
fixed by the trial Court.
8. It is, however, clarified that the observations made
Patna High Court CR. MISC. No.35047 of 2026(2) dt.10-07-2026
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herein are limited to the adjudication of the present anticipatory
bail application and shall not prejudice the case of the petitioner
at any subsequent stage of the trial and this Court has not
expressed any opinion on the merits of the case.
(Sandeep Kumar, J)
Shishir/-
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