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Patna High Court

Vikrama Singh @ Bikrama SinghversusThe State of Bihar

Decided
Disposal
BAIL GRANTED

Holding

The Court granted bail to the petitioners, subject to a bond and conditions under Section 482(2) of the B.N.S.S., 2023.

Summary

Vikrama Singh and Phula Devi, the elderly father‑in‑law and mother‑in‑law of a deceased woman, were named in an FIR (Tarari PS Case No. 166 of 2025) alleging dowry demand, threat and disappearance under Sections 80, 238(a) and 3(5) of the Bharatiya Nyaya Sanhita, 2023. They sought bail, asserting innocence, that the alleged motorcycle and money demands were false, and that the husband of the deceased was already in custody. The State opposed bail but acknowledged the petitioners' advanced age. The Court examined the allegations, the petitioners' clean antecedent and the fact that the primary accused (the husband) was already detained. It ordered that the petitioners be released on bail upon furnishing a bond of Rs.30,000 each, subject to conditions under Section 482(2) of the B.N.S.S., 2023.

Issues considered

  • Whether bail should be granted to the petitioners under the Bharatiya Nyaya Sanhita, 2023 in view of the allegations of dowry demand and threat.
  • Whether the petitioners' age and clean antecedent warrant bail despite the seriousness of the offences alleged.

Legislation cited

Subjects

  • bail
  • dowry death
  • Bharatiya Nyaya Sanhita
  • criminal procedure
  • elderly accused
  • Section 80
  • Section 238
  • Section 3(5)
  • Section 482
  • Section 2(1)(d)

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.36091 of 2026
                       Arising Out of PS. Case No.-166 Year-2025 Thana- TARARI District- Bhojpur
                 ======================================================
           1.     Vikrama Singh @ Bikrama Singh S/O Late Bhola Singh R/O Village and
                  Post- Gahrua, P.S- Tarari, Distt.- Bhojpur, Bihar.
           2.    Phula Devi @ Fula Devi @ Shobha Devi W/O Vikrama Singh @ Bikrama
                 Singh R/O Village and Post- Gahrua, P.S- Tarari, Distt.- Bhojpur, Bihar.

                                                                                   ... ... Petitioner/s

                                                       Versus

                 The State of Bihar

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :       Ms. Riya Raj, Adv.
                 For the Opposite Party/s :       Mr. Jagdhar Prasad, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE DR. ANSHUMAN
                                       ORAL ORDER

2   01-06-2026                  The Court proceeding is being conducted through

                   virtual mode.

                                2. Heard learned counsel for the petitioners and

                   learned APP for the State.

                                3. The petitioners are apprehending arrest in

                   connection with Tarari P.S. Case No. 166 of 2025, lodged on

                   30.09.2025, for the offence punishable under Sections 80,

                   238(a) & 3(5) of the Bharatiya Nyaya Sanhita, 2023.

                                4. As per the prosecution, FIR has been lodged against

                   five named accused persons including the present petitioners.

                   The marriage of the informant’s daughter solemnized with the

                   petitioners’ son on 28.05.2025. Subsequently, the demand of
Patna High Court CR. MISC. No.36091 of 2026(2) dt.01-06-2026
                                            2/3




          dowry is there and the allegation of threat is also there in the

          FIR. On 26.09.2025, the husband of the deceased has called the

          informant that his daughter is ill and requested to reach the

          hospital and when they reached the hospital then they found that

          his daughter is not there. Thereafter, the informant with his son

          and wife went to her daughter’s sasural, then they got

          information that all the accused persons fled away from the

          house.

                       5. Learned counsel for the petitioners submit that the

          petitioners are innocent and have committed no offence.

          Counsel submits that the entire allegation is false and the

          demand of motorcycle and money is also false, as the said

          motorcycle is registered in the name of informant’s son. He

          submits that in this case, the husband of the deceased is already

          in custody since 15.10.2025 and the present petitioners are

          father in law and mother in law of the deceased, aged about 75

          years and 66 years respectively. Counsel submits that with

          regard to their innocence, the representation has been made to

          the Superintendent of Police, Bhojpur at Ara. He submits that

          marriage card has been annexed as Annexure-P/2 by which it

          become crystal clear that the deceased visited to her maika one

          day before her death. He further submits that the petitioners
             Patna High Court CR. MISC. No.36091 of 2026(2) dt.01-06-2026
                                                         3/3




                       have clean antecedent.

                                    6. Learned APP for the State opposes the prayer for

                       bail of the petitioners but fairly submits that the husband of the

                       deceased is already in custody as per the pleading and the

                       present petitioners are father in law and mother in law of the

                       deceased, aged about 75 years and 66 years respectively.

                                    7. As such, in the present facts and circumstances of

                       this case, let the above named petitioners be released on bail, in

                       the event of arrest or surrender before the Trial Court within a

                       period of 4 weeks from today, on furnishing bail bond of

                       Rs.30,000/- (Rupees Thirty Thousand) each as mentioned in

                       Section 2(1)(d) of the B.N.S.S., 2023 to the satisfaction of

                       J.M.F.C., Bhojpur, Ara, in connection with Tarari P.S. Case No.

                       166 of 2025, subject to the conditions as laid down U/s 482(2)

                       of the B.N.S.S., 2023.



                                                                       (Dr. Anshuman, J)
Divyansh/-

U      T


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