Patna High Court
Runa DeviversusThe State of Bihar
- Decided
- Disposal
- BAIL REJECTED
- Bench
- PRABHAT KUMAR SINGH
Holding
Anticipatory bail was denied as the allegations were serious and the death occurred under suspicious circumstances within seven years of marriage.
Summary
The petitioner, Runa Devi, mother‑in‑law of a deceased woman, sought anticipatory bail in a dowry‑death case registered under Sections 80 and 3(5) of the Bharatiya Nyaya Sanhita. The prosecution alleged that she, along with co‑accused, tortured and killed the daughter‑in‑law for non‑payment of dowry. The petitioner argued she had no involvement, was separate in property, and had a clean antecedent, contending the informant was not an eye‑witness. The State opposed bail, emphasizing the direct allegation against the petitioner and the unnatural death within seven years of marriage in the in‑laws’ house. The Court, considering the seriousness of the accusation and the circumstances of the death, rejected the petition for anticipatory bail.
Issues considered
- Whether anticipatory bail can be granted to the mother‑in‑law under Sections 80 and 3(5) of the Bharatiya Nyaya Sanhita in a dowry‑death case.
Legislation cited
- Bharatiya Nyaya Sanhita — s. 3(5), 80
Subjects
- dowry death
- anticipatory bail
- Bharatiya Nyaya Sanhita
- criminal procedure
- mother‑in‑law liability
Judgment
IN THE HIGH COURT OF JUDICATURE AT PATNA
CRIMINAL MISCELLANEOUS No.4243 of 2026
Arising Out of PS. Case No.-302 Year-2025 Thana- TEGHRHA District- Begusarai
======================================================
Runa Devi W/o Laxmi Ray Resident of Village- Gaura 01, Ward No. 12, P.S.-
Teghra, District- Begusarai
... ... Petitioner/s
Versus
The State of Bihar
... ... Opposite Party/s
======================================================
Appearance :
For the Petitioner/s : Mr. Raj Kumar Sinha, Advocate
For the Opposite Party/s : Ms. Pushpa Sinha, A.P.P.
======================================================
CORAM: HONOURABLE MR. JUSTICE PRABHAT KUMAR SINGH
ORAL ORDER
2 19-02-2026 Heard learned counsel for the petitioner and the State.
2. Petitioner apprehends arrest in Teghra P. S. Case
No. 302 of 2025 registered for the offences punishable under
Sections 80 and 3(5) of the Bharatiya Nyaya Sanhita.
3. It is a case of dowry death. As per the prosecution
case, the daughter of informant got married with co-accused
Saurav Kumar in the year 2021. Later on, this petitioner along
with other co-accused persons started subjecting her to torture
and harassment for non-fulfillment of demand of dowry and
ultimately, accused persons killed the deceased.
4. Learned counsel for the petitioner submitted that
petitioner is mother-in -law of deceased. Informant is not an eye
witness and only a suspicion has been raised against this
petitioner. Petitioner is separate in mess and property and has
Patna High Court CR. MISC. No.4243 of 2026(2) dt.19-02-2026
2/2
got no concern with the affairs of deceased and her husband.
Thrust of accusation is against husband of the deceased.
Petitioner claims clean antecedent.
5. Learned A.P.P. for the State opposed the prayer for
bail and submits that petitioner is mother-in-law of the deceased
and there is direct and specific allegation that she along with
other co-accused persons killed the deceased due to non-
fulfillment of dowry demand. The deceased died in unnatural
circumstances within 7 years of marriage in her matrimonial
house.
6. Considering the nature of accusation and the fact
that deceased died in unnatural condition within 7 years of
marriage in her in-laws’ house, prayer for anticipatory bail of
the petitioner is rejected.
(Prabhat Kumar Singh, J)
Navya/-
U T
Checking your session…