Patna High Court
Ranju DeviversusThe State of Bihar
- Decided
- Disposal
- ALLOWED
- Bench
- SUNIL DUTTA MISHRA
Holding
The court held that, given the petitioner’s clean antecedent and lack of direct involvement, bail should be granted subject to conditions under Section 482(2) of the Bharatiya Nagarik Suraksha Sanhita.
Summary
Ranju Devi, the mother‑in‑law of a deceased woman, feared arrest in a case registered under Sections 85, 80, 238 and 3(5) of the Bharatiya Nyaya Sanhita alleging that she and others killed the informant’s sister over a dowry dispute. She contended that she was falsely implicated, had no criminal record, and the FIR was lodged after an unexplained two‑day delay. The State opposed her bail application. The court, noting her clean antecedent, lack of direct involvement, and the circumstances of the FIR, granted her bail on condition of a Rs 10,000 bond with two sureties, subject to Section 482(2) of the Bharatiya Nagarik Suraksha Sanhita.
Issues considered
- Whether the petitioner is entitled to bail despite the serious nature of the allegations under the Bharatiya Nyaya Sanhita.
- Whether the delay in filing the FIR and the petitioner’s clean antecedent justify granting bail.
- Whether the conditions imposed under Section 482(2) of the Bharatiya Nagarik Suraksha Sanhita are appropriate.
Legislation cited
- Bharatiya Nagarik Suraksha Sanhita — s. 482(2)
- Bharatiya Nyaya Sanhita — s. 238, 3(5), 80, 85
Subjects
- bail
- dowry death
- criminal procedure
- Bharatiya Nyaya Sanhita
- Bharatiya Nagarik Suraksha Sanhita
- clean antecedent
- suspicion
Judgment
IN THE HIGH COURT OF JUDICATURE AT PATNA
CRIMINAL MISCELLANEOUS No.4268 of 2026
Arising Out of PS. Case No.-707 Year-2024 Thana- DHANARUA District- Patna
======================================================
Ranju Devi Wife of Late Upendra Prasad R/o Maner, P.O. - Sonmai, P.S. -
Dhanarua, Dist. - Patna.
... ... Petitioner/s
Versus
The State of Bihar
... ... Opposite Party/s
======================================================
Appearance :
For the Petitioner/s : Mr. Lallu Prasad, Advocate
For the Opposite Party/s : Mr. Anil Kumar, APP
======================================================
CORAM: HONOURABLE MR. JUSTICE SUNIL DUTTA MISHRA
ORAL ORDER
3 01-04-2026 Heard learned counsel for the petitioner and
learned A.P.P. for the State.
2. The petitioner apprehends her arrest in a case
registered under Sections 85, 80, 238 and 3(5) of the Bharatiya
Nyaya Sanhita.
3. As per the F.I.R., it is alleged that due to non-
fulfillment of dowry demand, all the accused persons including
the petitioner killed the sister of the informant.
4. Learned counsel appearing on behalf of the
petitioner submits that petitioner is innocent and has falsely
been implicated in the present case only on the basis of
suspicion. Further submission is that petitioner is mother-in-law
of the deceased and she has no concern with the matrimonial
affairs of the deceased and her husband. The F.I.R. has been
Patna High Court CR. MISC. No.4268 of 2026(3) dt.01-04-2026
2/2
lodged after a delay of two days without any plausible
explanation. The husband of the deceased is already under
judicial custody. Petitioner has got no criminal antecedent and
she undertakes to cooperate in the investigation and trial.
5. Learned A.P.P. for the State opposed the prayer for
bail.
6. Having considered the facts and circumstances of
the case, submissions of learned counsel for the parties, nature
of allegation and clean antecedent of the petitioner, let the above
named petitioner be released on bail, in the event of arrest or
surrender before the learned court below within a period of six
weeks from today, on furnishing bail bond of Rs.10,000/-
(Rupees Ten Thousand) with two sureties of the like amount
each to the satisfaction of learned Sub-Divisional Judicial
Magistrate, Masaurhi, Patna in connection with Dhanarua P.S.
Case No. 707 of 2024, subject to the conditions as laid down
under Section 482(2) of the Bharatiya Nagarik Suraksha
Sanhita.
(Sunil Dutta Mishra, J)
utkarsh/-
U T
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