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Patna High Court

Urmila DeviversusThe State of Bihar

Decided
Disposal
BAIL GRANTED

Holding

The court granted regular bail to the petitioners, directing them to furnish a bail bond of Rs.10,000 with two sureties each.

Summary

The petitioners, Urmila Devi and Lalendra Yadav, applied for regular bail in a case registered under Sections 80(2), 238(b) and 3(5) of the B.N.S., alleging that the death of the informant's daughter was due to a snake bite and not a dowry‑related homicide. The prosecution claimed the petitioners were involved in the murder to satisfy dowry demands. The petitioners contended that the allegations were false, that the husband of the deceased was already in judicial custody, and that they had no prior criminal record. The State opposed the bail, but the court considered the facts, the length of custody, and the lack of antecedents. The court ordered that both petitioners be released on bail upon furnishing a bail bond of Rs.10,000 with two sureties each, and the application was allowed.

Issues considered

  • Whether regular bail should be granted to the petitioners under Sections 80(2), 238(b) and 3(5) of the B.N.S. in view of the alleged dowry‑related death and the circumstances of custody.

Legislation cited

  • B.N.S. — s. 238(b), 3(5), 80(2)

Subjects

  • regular bail
  • dowry death
  • false allegations
  • snake bite
  • criminal procedure
  • B.N.S.
  • Sections 80, 238, 3

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.3875 of 2026
                    Arising Out of PS. Case No.-188 Year-2024 Thana- BHAGWANGANJ District- Patna
                 ======================================================
           1.     Urmila Devi Son of Lalendra Yadav Resident of Village - Nadauna, P.S.-
                  Bhagwanganj, District - Patna.
           2.     Lalendra Yadav Son of Late Munsi Yadav Resident of Village - Nadauna,
                  P.S.- Bhagwanganj, District - Patna.
                                                                         ... ... Petitioner/s
                                                     Versus
                 The State of Bihar
                                                                  ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :      Mr. Sheonandan Pandit, Advocate
                 For the Opposite Party/s :      Mr. Narsingh Tanti, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE PRAVEEN KUMAR
                                       ORAL ORDER

4   06-04-2026                  Heard learned counsel for the petitioners and learned

                   APP for the State.

                                2. The petitioners have preferred this application for

                   grant of regular bail in connection with Bhagwanganj P.S. Case

                   No. 188 of 2024 dated 15.10.2024 registered for the offences

                   punishable under Sections 80(2), 238(b) and 3(5) of B.N.S.

                                3. As per the prosecution case, the daughter of the

                   informant was married with co-accused Rahul in the year 2023.

                   Thereafter, the informant got an information that his daughter

                   has been killed by these petitioners and other family members

                                4. Learned counsel for the petitioners has submitted

                   that the petitioners are mother-in-law and father-in-law

                   respectively of the deceased and, in fact, the allegation of torture

                   for non-fulfillment of dowry demand is false, the deceased died
           Patna High Court CR. MISC. No.3875 of 2026(4) dt.06-04-2026
                                                       2/2




                     due to snake bite and the same was within the knowledge of the

                     informant, but subsequently in order to blackmail, the present

                     case has been lodged. It has further been submitted that husband

                     of the deceased is in judicial custody since 02.11.2024 and the

                     said fact has been brought on record by way of filling

                     supplementary affidavit.           It has been further submitted that

                     petitioner No.1 is in custody since 03.08.2025 and petitioner

                     No.2 is in custody since 18.08.2025 having no criminal

                     antecedent.

                                  5. Learned A.P.P. for the State has vehemently

                     opposed the bail petition of the petitioners.

                                  6. Considering the aforesaid facts and circumstances

                     of the case as well as the period of custody, the petitioners

                     above-named, are directed to be enlarged on bail on furnishing

                     bail-bond of Rs.10,000/- (Rupees Ten Thousand) each with two

                     sureties of the like amount each to the satisfaction of learned

                     Court concerned, Masaurhi, in connection with Bhagwanganj

                     P.S. Case No. 188 of 2024.

                                  7. The application stands allowed.



                                                (Praveen Kumar, J)
shivam/-

U      T


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