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Patna High Court

Vikas RanjanversusThe State of Bihar

Decided
Disposal
BAIL GRANTED

Holding

The High Court quashed the criminal proceedings on the ground of the parties’ settlement and dissolution of marriage, rendering the anticipatory bail application infructuous.

Summary

Vikas Ranjan filed applications before the Patna High Court seeking to quash criminal proceedings (Cr. Misc. Nos. 53810 and 27233 of 2024) that had been instituted under IPC sections 341, 323, 504, 506, 498A/34 and the Domestic Violence Act sections 3 and 4. The petitioner produced a judgment of the Principal Judge of the Family Court, Aurangabad, dated 10 January 2026, which dissolved the marriage in Matrimonial Case No. 147 of 2025 and recorded a settlement complied with by both parties. The informant‑wife also affirmed the settlement. The Court held that, in view of the dissolution of marriage and the parties’ settlement, the criminal proceedings should be quashed. Accordingly, the order dated 11 January 2024 of the Sub‑Divisional Judicial Magistrate was set aside and all consequential proceedings were dismissed. A separate anticipatory bail application filed by the petitioner was dismissed as infructuous because the prosecution itself had been quashed.

Issues considered

  • Whether criminal proceedings instituted under the IPC and the Domestic Violence Act can be quashed after the parties have dissolved their marriage and reached a settlement.
  • Whether an anticipatory bail application remains viable when the underlying prosecution has been quashed.

Legislation cited

Subjects

  • criminal procedure
  • quash of criminal proceedings
  • anticipatory bail
  • marital settlement
  • domestic violence
  • IPC
  • Family Court judgment

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.27233 of 2024
                     Arising Out of PS. Case No.-22 Year-2023 Thana- MAHILA PS District- Aurangabad
                  ======================================================
                  Vikas Ranjan Son of Madhusudan Singh Resident of Aditya Niwas, Nand
                  Nagar, Harmu, P.S.- Argora, Distt.-Ranchi, (Jharkhand)

                                                                                   ... ... Petitioner/s
                                                        Versus
            1.    The State of Bihar Bihar
            2.    Julie Kumari Wife of Vikash Ranjan Resident of Siyadih, P.S.-Konch, Distt.-
                  Gaya at present C/o Umashanker Singh, resident of Thana Road, Madanpur,
                  P.S.-Madanpur, Distt.-Aurangabad(Bihar)

                                                         ... ... Opposite Party/s
                  ======================================================
                                                          with
                             CRIMINAL MISCELLANEOUS No. 53810 of 2024
                     Arising Out of PS. Case No.-22 Year-2023 Thana- MAHILA PS District- Aurangabad
                  ======================================================
                  Vikas Ranjan S/o Madhusudan Singh R/o Aditya Niwas, Nand Nagar Harmu,
                  P.s. - Doranda, Distt. - Ranchi (Jharkhand)

                                                                                   ... ... Petitioner/s
                                                        Versus
            1.    The State of Bihar Bihar
            2.    Julie Kumari W/o Vikas Ranjan R/o Siyadih, p.S. - Konch, Distt. - gaya at
                  present C/o Umashanker Singh, R/o Thana Road, Madanpur, P.s. -
                  Madanpur, Distt. - Aurangabad (Bihar)

                                                         ... ... Opposite Party/s
                  ======================================================
                  Appearance :
                  (In CRIMINAL MISCELLANEOUS No. 27233 of 2024)
                  For the Petitioner/s     : Mr. Gopal Pd. Rai
                                             Mr.Rajani Kant Mishra
                  For the Opposite Party/s : Mr.Anant Kumar 1
                  (In CRIMINAL MISCELLANEOUS No. 53810 of 2024)
                  For the Petitioner/s     : Mr. Gopal Pd. Rai
                                             Mr.Rajani Kant Mishra
                  For the Opposite Party/s : Mr.Manoj Kumar
                  ======================================================
                  CORAM: HONOURABLE MR. JUSTICE SANDEEP KUMAR
                                        ORAL ORDER

10   10-02-2026                   Re:- Criminal Misc. No. 53810 of 2024

                                Heard the parties.
Patna High Court CR. MISC. No.27233 of 2024(10) dt.10-02-2026
                                            2/3




                       2. This application has been filed on behalf of the

          petitioner for quashing the order dated 11.01.2024 passed by the

          Sub-Divisional Judicial Magistrate, Aurangabad in Mahila P.S.

          Case No. 22 of 2023 by which the cognizance has been taken

          against the petitioner under Sections 341, 323, 504, 506,

          498A/34 of the Indian Penal Code and under Sections 3 and 4 of

          the D.P. Act.

                       3. Learned counsel for the petitioner, at the very

          outset, has produced a copy of the judgment dated 10.01.2026

          passed by the Principal Judge, Family Court, Aurangabad

          passed in Matrimonial Case No. 147 of 2025 which has been

          disposed and the marriage has been dissolved. The terms of the

          settlement for dissolution of marriage have also been complied

          by both the parties.

                       4. Learned counsel for the informant-wife has also

          supported the fact of settlement between the parties.

                       5. In view of the above, this application is allowed

          and accordingly, the order dated 11.01.2024 passed by the Sub-

          Divisional Judicial Magistrate, Aurangabad in Mahila P.S. Case

          No. 22 of 2023 and all consequential proceedings arising out of

          the same is hereby quashed.

                          Re:- Criminal Miscellaneous No. 27233 of 2024.
          Patna High Court CR. MISC. No.27233 of 2024(10) dt.10-02-2026
                                                      3/3




                                    6. Heard the parties.

                                    7. Though this application has been preferred for

                    grant of anticipatory bail to the petitioner but in view of the fact

                    that entire prosecution of the petitioner has been quashed vide

                    Criminal Misc. No. 53810 of 2024, this application has become

                    infructuous.

                                    8. Accordingly, this application is dismissed has

                    having infructuous.



                                                             (Sandeep Kumar, J)
Vikas/-

U


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