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Patna High Court

Sonu Sangahi @ Sonu KumarversusThe State of Bihar

Decided
Disposal
BAIL GRANTED

Holding

The court granted anticipatory bail to the petitioner, directing his release on bond and sureties.

Summary

The petitioner, Sonu Sangahi, was named in an FIR for alleged involvement in the death of his sister‑in‑law, the daughter of the informant, allegedly due to non‑fulfilment of a dowry demand for a Scorpio car. The petitioner argued that the dowry demand was made collectively by seven co‑accused and that his role was limited to a reminder, not a specific demand, and that the death appeared to be a suicide based on the post‑mortem. The State contended that the death was a dowry‑related homicide and that the petitioner was part of the conspiracy. The court examined the lack of direct assault allegations against the petitioner, the ambiguous cause of death, and the fact that other co‑accused had already been granted anticipatory bail. Finding insufficient grounds to deny bail, the court ordered the petitioner’s release on bail with a bond and sureties, subject to Section 482(2) of the BNSS.

Issues considered

  • Whether the petitioner is entitled to anticipatory bail despite being named in the FIR for dowry death.
  • Whether the dowry demand was specifically made by the petitioner or was a general demand by co‑accused.
  • Whether the death of the informant's daughter can be conclusively linked to dowry demand or is a suicide.

Legislation cited

Subjects

  • dowry death
  • anticipatory bail
  • Section 80
  • Section 3(5)
  • Section 482(2)
  • suicide
  • brother‑in‑law
  • criminal procedure

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.40200 of 2026
                       Arising Out of PS. Case No.-13 Year-2026 Thana- BIHPUR District- Bhagalpur
                 ======================================================
                 Sonu Sangahi @ Sonu Kumar Son of Yamuna Sangahi Resident of Village
                 Amarpur, P.S.- Bihpur, District - Bhagalpur
                                                                     ... ... Petitioner/s
                                                     Versus
                 The State of Bihar
                                                              ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :        Mr. Ajay Thakur, Adv
                                          :        Mr. Anupa Nand Jha, Adv
                 For the Opposite Party/s :        Mr. Ramchandra Sahni, APP
                 For the Informant        :        Mr. Deepak Kumar, Adv
                                          :        Ms. Parishmita Bora, Adv
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE CHANDRA SHEKHAR JHA
                                       ORAL ORDER

2   23-06-2026                    Heard the parties.

                                 2. The petitioner is named in the F.I.R. and

                   apprehending his arrest in connection with Bihpur P.S. Case No.

                   13/2026 registered for the offences punishable under Sections 80

                   and 3(5) of the BNS

                                 3. The allegation against petitioner is to cause death of

                   daughter of informant along with other co-accused persons/family

                   members due to non-fulfillment of demand of dowry as raised for

                   one scorpio car.

                                 4. Mr. Ajay Thakur, learned counsel appearing on

                   behalf of the petitioner submitted that from the perusal of FIR it

                   appears clearly at first instance that demand of scorpio car as

                   dowry was made entirely by 7 co-accused persons including this
Patna High Court CR. MISC. No.40200 of 2026(2) dt.23-06-2026
                                            2/4




          petitioner and, therefore, it can be said safely that demand was

          general and omnibus. In this context it is further pointed out that

          subsequently, it is alleged regarding this petitioner that he

          reminded aforesaid demand to informant on 14.01.2026, while

          he visited his home on the occasion of Tila Sankranti. It is

          submitted that raising demand of dowry and reminding demand

          of dowry are two different aspects. It is further submitted that

          through same FIR it is alleged that daughter of informant

          witnessed her husband establishing physical relationship with wife

          of his elder brother due to which, she was assaulted by her

          mother-in-law and wife of his elder brother on 16.01.2026 the

          day on which she died in her matrimonial home. It is submitted

          that allegation of assault is not available against this petitioner as

          same is available against mother-in-law and elder sister-in-law

          (jethani), who have already granted anticipatory bail by learned

          trial court, itself. It is submitted that allegation of demand of

          scorpio is also available against mother-in-law, elder sister-in-law,

          though it was general and omnibus in nature and merely it was

          alleged to remind by petitioner, while visiting the house of the

          informant on 14.01.2026, it cannot be said that aforesaid

          demand was raised specifically by this petitioner, who is brother-

          in-law.
Patna High Court CR. MISC. No.40200 of 2026(2) dt.23-06-2026
                                            3/4




                        5. It is submitted that out of oblique motive to harras

          the entire family members, the petitioner being brother-in-law

          implicated with the present case, otherwise having no connection

          with daily and domestic affairs with deceased and her husband.

          Petitioner claimed clean antecedent.

                        6. Learned APP duly assisted by learned counsel for

          the informant, while opposing the prayer of bail submitted that

          daughter of informant was killed within two months of the

          marriage in her matrimonial home due to non-fulfillment of

          demand of dowry. However, he fairly conceded that mother-in-

          law and elder sister-in-law were granted anticipatory bail by

          learned trial court, itself for which cancellation of bail has already

          been filed.

                           7. Countering aforesaid submission, Mr. Thakur

          submitted that the aforesaid argument as daughter of informant

          was killed not appears convincing, in view of post-mortem of the

          deceased, which suggest she committed suicide as except ligature

          mark no injury was found upon her body as alleged. It is

          submitted that occurrence is also doubtful, whether it was caused

          due to non-fulfillment of demand of dowry or was due to illicit

          relationship. It is also submitted that post-mortem failed to

          opined cause of death and still the opinion is awaited in this
               Patna High Court CR. MISC. No.40200 of 2026(2) dt.23-06-2026
                                                           4/4




                         regard.

                                         8. In view of aforesaid factual submission and by

                         taking note of fact as petitioner is brother-in-law of the deceased,

                         against whom allegation of assault is not available, where

                         informant prima-facie not sure whether occurrence took place

                         due to non-fulfillment of dowry demand or illicit relationship of

                         husband of the deceased with wife of his elder brother ( bhabhi),

                         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 JM 1 st Class,

                         Naugachiya/concerned Court, where the case is pending in

                         connection with Bihpur P.S. Case No. 13/2026, subject to the

                         conditions as laid down under Section 482(2) of BNSS.


                                               (Chandra Shekhar Jha, J)
S.Tripathi/-

U       T


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