Patna High Court
Ranjana Devi @ Ranjana SinghversusThe State of Bihar
- Decided
- Disposal
- BAIL GRANTED
- Bench
- RAJESH KUMAR VERMA
Holding
The court granted bail to the petitioner subject to specified conditions.
Summary
Ranjana Devi, the mother‑in‑law of a deceased woman, was arrested in connection with a dowry‑death case under Sections 80, 61 and 3(5) of the Bharatiya Nyaya Sanhita, 2023. The prosecution alleged that she, along with co‑accused, killed the victim for non‑payment of dowry. The petitioner argued she has a clean antecedent and was implicated only because of her familial relationship, noting no specific act or demand of dowry against her. The Additional Public Prosecutor opposed bail. The court, after considering the circumstances, ordered her release on bail of Rs.10,000 with two sureties, subject to conditions of cooperation, non‑tampering with evidence, and verification of criminal antecedent.
Issues considered
- Whether bail should be granted to the accused mother‑in‑law in a dowry‑death case under the Bharatiya Nyaya Sanhita, 2023.
Legislation cited
- Bharatiya Nyaya Sanhita, 2023 — s. 3(5), 61, 80
Subjects
- dowry death
- bail
- Bharatiya Nyaya Sanhita
- criminal procedure
- mother‑in‑law
- Section 80
- Section 61
- Section 3(5)
Judgment
IN THE HIGH COURT OF JUDICATURE AT PATNA
CRIMINAL MISCELLANEOUS No.38893 of 2026
Arising Out of PS. Case No.-22 Year-2026 Thana- LALIT NARAYAN UNIVERSITY
District- Darbhanga
======================================================
Ranjana Devi @ Ranjana Singh Wife of Chandra Prakash Singh R/o Teghra,
Hasanpur, P.S-Teghra, District-Begusarai
... ... Petitioner/s
Versus
The State of Bihar
... ... Opposite Party/s
======================================================
Appearance :
For the Petitioner/s : Ms. Kanchan Jha, Advocate
For the Opposite Party/s : Mr. Satyendra Prasad, APP
======================================================
CORAM: HONOURABLE MR. JUSTICE RAJESH KUMAR VERMA
ORAL ORDER
2 22-06-2026 Heard Ms. Kanchan Jha,learned counsel for the
petitioner as well as Mr. Satyendra Prasad, learned Additional
Public Prosecutor for the State.
2. Petitioner seeks bail who is in custody since
29.01.2026 in connection with LNMU P.S. Case No. 22 of 2026,
F.I.R. dated 27.01.2026 for the offences punishable under
Sections 80, 61 and 3(5) of Bharatiya Nyaya Sanhita, 2023.
3. According to prosecution case, the informant
alleged that the petitioner along with other co-accused persons
killed his sister, namely, Anisha Kumari (now, deceased) due to
non-fulfillment of demand of dowry.
4. Learned counsel for the petitioner submits that
petitioner has clean antecedent and she has falsely been
Patna High Court CR. MISC. No.38893 of 2026(2) dt.22-06-2026
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implicated in the present case merely on the basis that she is the
mother-in-law of the deceased. From bare perusal of the FIR, it
appears that there is no specific assault or overt act or demand
of dowry against the petitioner rather the allegation levelled
against her is general and omnibus in nature. In fact, after the
child birth the deceased had developed severe health
complications and during treatment she died. He further submits
that husband of the deceased, who happens to be the son of the
petitioner is in judicial custody since 29.01.2026 and police
after investigation has submitted chargesheet. The petitioner is
in custody since 29.01.2026.
5. Learned Additional Public Prosecutor has
vehemently opposed the prayer for bail of the petitioner.
6. Considering the aforesaid facts and circumstances,
let the petitioner, above named, be released on bail on furnishing
bail bond of Rs. 10,000/- (Ten Thousand) with two sureties of
the like amount each to the satisfaction of the learned C.J.M.,
Darbhanga in connection with L.N.M.U. P.S. Case No. 22 of
2026, subject to the following conditions:-
i. Petitioner shall co-operate in the trial and shall be
properly represented on each and every date fixed by the court
and shall remain physically present as directed by the court and
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on her absence on two consecutive dates without sufficient
reason, his bail bond shall be cancelled by the Court below.
ii. If the petitioner tampers with the evidence or the
witnesses, in that case, the prosecution will be at liberty to
move for cancellation of bail.
iii. And further condition that the court below shall
verify the criminal antecedent of the petitioner and in case at
any stage it is found that the petitioner has concealed her
criminal antecedent, the court below shall take step for
cancellation of bail bond of the petitioner. However, the
acceptance of bail bonds in terms of the above-mentioned order
shall not be delayed for purpose of or in the name of
verification.
(Rajesh Kumar Verma, J)
Suruchi /-
U T
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