Patna High Court
Ravi Ranjan KumarversusThe State of Bihar
- Decided
- Disposal
- BAIL GRANTED
- Bench
- SANDEEP KUMAR
Holding
The High Court held that anticipatory bail is appropriate and granted it subject to specified conditions.
Summary
Petitioner Ravi Ranjan Kumar sought anticipatory bail fearing arrest in a complaint (No. 630 of 2024) alleging offences under IPC sections 323, 379, 498A and Section 3 of the Dowry Prohibition Act. The prosecution alleged that the petitioner, along with others, assaulted and tortured the victim to extract dowry. The petitioner contended innocence and applied for anticipatory bail. Relying on the Supreme Court’s directive in Arnesh Kumar v. State of Bihar, the High Court held that an arrest was not mandatory and granted anticipatory bail under Section 438(2) of the CrPC, subject to a bail bond, sureties and a monthly maintenance payment of Rs. 5,000 to the complainant. The order also made the maintenance condition contingent on any pending family‑court proceedings and warned that non‑compliance could lead to cancellation of bail.
Issues considered
- Whether anticipatory bail can be granted in a case involving alleged assault, robbery and dowry‑related offences.
- Whether the principles laid down in Arnesh Kumar v. State of Bihar apply to restrain unnecessary arrest.
- Whether the High Court may impose a maintenance payment as a condition of anticipatory bail.
Legislation cited
- Criminal Procedure Code — s. 438(2), 482
- Dowry Prohibition Act — s. 3
- Indian Penal Code — s. 323, 379, 498A
Subjects
- anticipatory bail
- Section 438 CrPC
- Arnesh Kumar principle
- dowry harassment
- IPC offences
- maintenance order
- high court bail conditions
Judgment
IN THE HIGH COURT OF JUDICATURE AT PATNA
CRIMINAL MISCELLANEOUS No.37192 of 2026
Arising Out of PS. Case No.-630 Year-2024 Thana- COMPLAINT CASE - PATNA CITY
District- Patna
======================================================
Ravi Ranjan Kumar Son of Ram Sujan Singh Resident of Village- Alipur,
P.S.- Salimpur, District- Patna
... ... Petitioner/s
Versus
1. The State of Bihar
2. Nisha Kumari Wife of Ravi Ranjan Kumar, D/o Sanoj Kumar Resident of
Village- Alipur, P.S.- Salimpur, District- Patna at present resident of
Gauripundha, P.S.- Fatuha, District- Patna
... ... Opposite Party/s
======================================================
Appearance :
For the Petitioner/s : Mr. Kahkashan Alam
For the Opposite Party/s : Mr. Shyam Kumar Singh
======================================================
CORAM: HONOURABLE MR. JUSTICE SANDEEP KUMAR
ORAL ORDER
2 15-06-2026 Heard the learned counsel for the petitioner and the
learned counsel for the State.
2. The petitioner apprehends his arrest in connection
with Complaint Case No. 630 of 2024 for the alleged offence
under Sections 323, 379 and 498A of the Indian Penal Code and
Section ¾ of the DP Act.
3. As per the prosecution case, the petitioner and
others are accused of assaulting and torturing the victim for
demand of dowry.
4. It has been submitted by the learned counsel for the
petitioner that the petitioner is innocent and he has falsely been
implicated in this case.
Patna High Court CR. MISC. No.37192 of 2026(2) dt.15-06-2026
2/3
5. Learned APP for the State has opposed the
application of the petitioner.
6. Considering the submission of the parties and in
light of the law laid down by the Hon’ble Supreme Court in the
case of Arnesh Kumar Vs. State of Bihar reported in (2014) 8
SCC 273, this application for grant of anticipatory bail is
allowed.
7. Let the petitioner, above named, in the event of his
arrest or surrender before the concerned Court below within four
weeks from today, be released on anticipatory bail on furnishing
bail bonds of Rs. 10,000/- (Ten Thousand) with two sureties of
the like amount each to the satisfaction of the learned Court
below where the case is pending/successor Court in connection
with Complaint Case No. 630 of 2024 subject to the conditions
laid down in Section 438(2) of the Code of Criminal Procedure,
1973 / Section 482 of the BNSS and with further condition that:
(I). The petitioner is directed to pay
a maintenance amount of Rs. 5000/- from the
month of June 2026 to the
complainant/informant. The maintenance for the
month of June 2026 shall be paid to the
complainant/informant within ten days from
today, and thereafter, the maintenance amount
shall be paid to the complainant/informant
every month before the 10th day of each month.
Patna High Court CR. MISC. No.37192 of 2026(2) dt.15-06-2026
3/3
8. It is made clear that the order of maintenance
passed by this Court shall be subject to the outcome of the
maintenance case in the Court of Principal Judge, Family Court
concerned, if any.
9. Needless to state that, if the petitioner fails to abide
by the terms and conditions, as stated hereinabove, the State
shall be at liberty to file an appropriate application, before the
learned concerned Court below for cancellation of bail granted
to the petitioner.
10. Let a copy of this order be communicated to the
Principal District & Sessions Judge, Patna through FAX for its
compliance forthwith.
(Sandeep Kumar, J)
Shishir/-
U T
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