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Patna High Court

ManikversusThe State of Bihar

Decided
Disposal
BAIL GRANTED

Holding

The Court held that the allegations were vague and omnibus, and therefore the petitioner was entitled to bail.

Summary

Manik Grover was named in a complaint (Case No. 1562 of 2023) alleging offences under IPC Sections 498A, 379, 120B and Section 3 of the Domestic Violence Act for mental and physical cruelty linked to a purported dowry demand of Rs 40 lakh. The petitioner contended that the demand was a loan, not dowry, and that the marriage was inter‑caste; he also argued that the complainant left voluntarily and that the allegations were vague and omnibus. The State opposed bail, asserting the dowry demand and consequent cruelty. The Court examined whether the allegations were specific enough to justify denial of bail and considered the applicability of Section 482(2) of the CrPC. Finding the accusations to be general and lacking specificity, the Court directed that the petitioner be released on bail upon furnishing a bond and sureties. The order was made subject to the conditions prescribed under Section 482(2) of the CrPC.

Issues considered

  • Whether the allegations under IPC Sections 498A, 379, 120B and the Domestic Violence Act are sufficient to deny bail.
  • Whether the complaint’s allegations are specific or merely general and omnibus.
  • Whether bail can be granted under Section 482(2) of the Criminal Procedure Code in the present circumstances.

Legislation cited

Subjects

  • dowry harassment
  • IPC 498A
  • bail
  • domestic violence
  • criminal conspiracy
  • mental cruelty
  • physical cruelty
  • inter-caste marriage

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.35507 of 2025
                  Arising Out of PS. Case No.-1562 Year-2023 Thana- GAYA COMPLAINT CASE District-
                                                          Gaya
                 ======================================================
                 Manik S/O Surendra Grover R/O 162 A, Model Town, Fatehabad, P.S-
                 Fatehabad, Haryana. At present, Bank of Maharashtra, Sahakar Nagar Parvati
                 Paitha, Pune (Maharashtra).

                                                                               ... ... Petitioner/s
                                                      Versus
           1.    The State of Bihar
           2.    Saloni W/O Manik R/O 162A, Model Town, Fatehbad, P.S- Fatehbad,
                 Haryana. At present residing at Flat No. D/302, Rajvila, Gaya dobhi Road,
                 New Airport, P.S- Magadh Medical College, Distt.- Gaya.

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s    :       Mr. Anuj Kumar, Adv.
                                                 Mr. Aditya Pandey, Adv.
                                                 Ms. Eashita Raj, Adv.
                 For the State           :       Mr. Md. Matloob Rab, Adv.
                 For the Opposite Party/s:       Mr. Rabia Gulnaz, Adv.
                                                 Mr. Ranjana Singh, Adv.
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE CHANDRA SHEKHAR JHA
                                       ORAL ORDER

7   21-01-2026                     Heard the parties.

                                 2. The petitioner is named in the complaint

                   case and apprehending his arrest in connection

                   with Complaint Case No. 1562 of 2023 registered

                   for the offences punishable under Sections 498A,

                   379, 120B of IPC and Section ¾ of D.P. Act.

                                 3. The allegation against petitioner is

                   commit           mental       and      physical         cruelty       upon

                   complainant due to non-fulfillment of demand of

                   dowry.
Patna High Court CR. MISC. No.35507 of 2025(7) dt.21-01-2026
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                       4. It is submitted by learned counsel

          appearing on behalf of the petitioner that even as

          per complaint petition it nowhere appears that the

          demand of dowry in actual was raised rather

          money was asked as a loan for purchasing flat. It is

          submitted that petitioner is a P.O. of bank, whereas

          O.P. No. 2/ complainant is a fashion designer and it

          was       inter       caste        marriage          and   when   the

          complainant faced inconvenience after joining her

          matrimonial home she left on her own.

                       5. Arguing further, learned counsel for

          petitioner drawn attention of this Court towards

          the Court question asked to complainant while

          recording her S.A. during inquiry that she would

          not even join this petitioner as to continue her

          marriage life even requested by her husband/

          petitioner.

                       6. Arguing further, it is submitted that the

          allegation is very much general and omnibus in

          nature as to implicate entire family members.

          While concluding argument, it is submitted that

          petitioner is a man of clean antecedent.
Patna High Court CR. MISC. No.35507 of 2025(7) dt.21-01-2026
                                            3/4




                       7. Learned APP opposes the prayer of bail.

                       8. Mrs. Rabia Gulnaz, learned counsel for

          the informant while opposing the prayer of bail

          submitted that the petitioner and his family

          member demanded dowry of Rs. 40 lakh and due

          to non-fulfillment of the same committed mental

          and physical cruelty upon complainant.

                       9. In view of aforesaid factual submission

          and by taking note of fact as allegation qua

          committing mental and physical assault appears

          very      much        general           and    omnibus   in   nature,

          accordingly petitioner above-named, in the event

          of his arrest or surrender before the court below

          within a period of four weeks, is directed to be

          released on bail,                 furnishing bail bond of Rs.

          10,000/- (Rupees Ten Thousand) with two sureties

          of the like amount each to the satisfaction of the

          learned SDJM, Gaya /concerned Court, where the

          case is pending in connection with Complaint Case

          No. 1562 of 2023 , subject to the conditions as laid

          down under Section 482(2) of BNSS.
              Patna High Court CR. MISC. No.35507 of 2025(7) dt.21-01-2026
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                                                                 (Chandra Shekhar Jha, J)
Sudha/-

U         T


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