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Patna High Court

Dr Pradeep Kumar Singh @ Pradeep SinghversusThe State of Bihar

Decided
Disposal
BAIL GRANTED

Holding

The court granted anticipatory bail to the petitioner, finding no sufficient ground to deny bail and imposing conditions under Section 438 CrPC.

Summary

Dr. Pradeep Kumar Singh sought anticipatory bail after a complaint was lodged under Sections 498A and 504 of the IPC and Section 4 of the Dowry Prohibition Act alleging dowry demands and cruelty. The petitioner claimed the allegations were false, stemming from a strained marital relationship and that his wife suffered from a mental disorder. The State and the complainant opposed bail, arguing the seriousness of the dowry demand and alleged abuse. The court examined the submissions, noting the lack of criminal antecedent and the petitioner’s willingness to comply with bail conditions. It granted anticipatory bail subject to strict conditions under Section 438 of the CrPC and Section 482(2) of the B.N.S.S.

Issues considered

  • Whether anticipatory bail should be granted in a case involving alleged dowry harassment under Sections 498A, 504 IPC and the Dowry Prohibition Act.
  • Whether the allegations against the petitioner are frivolous or warrant denial of bail.
  • Whether the petitioner poses a risk of fleeing, tampering with evidence, or influencing the investigation.

Legislation cited

Subjects

  • anticipatory bail
  • dowry harassment
  • Section 498A
  • Section 504
  • Dowry Prohibition Act
  • Criminal Procedure
  • bail conditions
  • marital dispute

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.54859 of 2025
                 Arising Out of PS. Case No.-625 Year-2024 Thana- ROHTAS COMPLAINT CASE District-
                                                         Rohtas
                 ======================================================
                 Dr Pradeep Kumar Singh @ Pradeep Singh S/O Hare Ram Singh Resident Of
                 Solanki House, Bhuyian Dih Near Bank of Baroda, P.S.- Sitaramdera, Dist.-
                 East Singhbhum (Jharkhand)-831009

                                                                               ... ... Petitioner/s

                                                     Versus

           1.    The State of Bihar
           2.    Dr Anupama Chauhan @ Kumari Anupama Chauhan D/O Arjun Kumar
                 Singh R/O Lane No. 10C, Kalavati Kunj, ekta chowk, P.S.- Sasaram, Dist.-
                 Rohtas, Bihar-831009

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s    :      Mrs. Nivedita Nirvikar, Sr. Advocate
                                                Mr. Amarshakti, Advcoate
                                                Mr. Shashank Shekhar, Advocate
                                                Ms. Riya Raj, Advocate
                 For the Opposite Party No.1:   Ms. Pushpa Sinha, APP
                 For the Opposite party No.2:   Mr. Sanjay Verma, Advocate
                                                Mr. Sanjay Sinha, Advocate
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE SOURENDRA PANDEY
                                       ORAL ORDER

4   21-01-2026                   Heard Ms. Nivedita Nirvikar, learned Senior counsel

                   assisted by Mr. Amarshakti, learned counsel, for the petitioner,

                   Mr. Sanjay Verma, learned counsel assisted by Mr. Sanjay

                   Sinha, learned counsel, for the opposite party no.2 and Ms.

                   Pushpa Sinha, learned APP for the State.

                                 2. Petitioner apprehends his arrest in connection with

                   Complaint Case No.625 of 2024 registered for the offences

                   under Sections 498(A) & 504 of the Indian Penal Code and
Patna High Court CR. MISC. No.54859 of 2025(4) dt.21-01-2026
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          Section 4 of the Dowry Prohibition Act, 1961.

                       3. As per the prosecution case, the complainant has

          alleged that during her marriage, her father had given

          Rs.30,00,000/- in cash and gold jewelry worth Rs.15,00,000/- as

          a gift, however, after few weeks of her marriage, her mother-in-

          law and sister-in-law Priya Singh started mocking her for

          getting less dowry and often pressurized the complainant for

          bringing money from her parents. It is further alleged that the

          petitioner, being the husband, also demanded Rs.50,00,000/-

          from the complainant for building a hospital and on account of

          non-fulfillment of the same, petitioner started abusing the

          complainant.

                       4. Learned Senior counsel for the petitioner submits

          that the present case is a fallout of strained relationship between

          the petitioner no.1 and opposite party no.2. It has been

          submitted that the petitioner happens to be a doctor and is a

          child specialist and false and frivolous allegations of demand of

          Rs.50,00,000/- for construction of hospital has been levelled

          only to settle personal scores.

                       5. Learned Senior counsel pointed out that the

          Petitioner, observing that his wife had not been behaving well,

          had even visited a psychiatrist, who disclosed that his wife was
Patna High Court CR. MISC. No.54859 of 2025(4) dt.21-01-2026
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          suffering from a disease, namely, Morbid Jealousy. It has been

          submitted that in fact this disease is genetic in the complainant's

          family and even the brother-in-law of the petitioner, namely,

          Abishek Anand, is getting treated for schizophrenia.

                       6. Learned Senior counsel has referred to the medical

          prescription brought on record by way of Annexure P-2 and has

          also drawn the attention of this Court towards Annexure P-3

          which are the bills and receipts which have been paid by the

          petitioner even during the marriage, contrary to the claim of the

          complainant. Learned Senior counsel has further taken this

          Court to Annexure P-4, which is the informatory petition lodged

          by the petitioner way back in 24.03.2023 apprehending false

          implication by the complainant and ultimately because of her

          attitude and looking at the fact that the relationship won't

          survive, a Matrimonial Suit No. 955 of 2023 was also filed on

          23.12.2023 in the Court of learned Principal Judge, Family

          Court, Jamsedpur and notice was issued to the opposite party

          no.2/complainant. It has been submitted by the learned Senior

          counsel that it was on account of such notice being received by

          the opposite party no.2 that the present complaint was filed with

          false and frivolous allegations and in fact this was the reason for

          the strained relationship, as the complainant was in the habit of
Patna High Court CR. MISC. No.54859 of 2025(4) dt.21-01-2026
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          picking fights on trivial issues. It has lastly been submitted that

          the petitioner has no criminal antecedent.

                       7. Learned APP for the State and learned counsel for

          the opposite party no.2 have vehemently opposed the prayer for

          bail and have stated that the allegation of petitioner being

          mentally unsound or suffering from some disease is all false and

          concocted and it is the subject matter of inquiry. It has next been

          submitted that there is specific allegation of demand of dowry

          for construction of hospital and abuse against the petitioner. It

          has also been stated that the petitioner has been ill-treating the

          complainant and ultimately, after being subjected to cruelty, the

          present case under Section 498A of the Indian Penal Code was

          lodged.

                       8. Considering the facts and circumstances of the case

          and the submissions advanced on behalf of the parties, let the

          petitioner above named be released on anticipatory bail, in the

          event of arrest or surrender before the learned Court below

          within a period of four weeks from today, on furnishing bail

          bonds of Rs.10,000/-(ten thousand) with two sureties of the like

          amount each to the satisfaction of the learned Court below

          where the case is pending/successor court in connection with

          Complaint Case No.625 of 2024, subject to the conditions as
              Patna High Court CR. MISC. No.54859 of 2025(4) dt.21-01-2026
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                        laid down under Section 438(2) of the Code of Criminal

                        Procedure read with corresponding Section 482(2) of B.N.S.S.

                        as well as subject to the following conditions:-

                                        (i) One of the bailors of the petitioner shall be his close
                                        relative.
                                        (ii) The petitioner shall remain physically present in
                                        Court on each date of the trial.
                                        (iii) In case of absence on two consecutive dates, or in
                                        violation of the terms of the bail, the bail bond of the
                                        petitioner will be liable to be cancelled by the Court
                                        concerned.
                                        (vi) The learned Court below shall verify the criminal
                                        antecedent of the petitioner and in case at any stage it is
                                        found that the petitioner has concealed his 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.
                                     9. Accordingly, the prayer for anticipatory bail is

                        allowed.

                                     10. It is made clear that the observation, if any, made

                        in this order, shall be of no bearing during the trial.



                                                 (Sourendra Pandey, J)
manoj/-

U         T


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