Patna High Court

Ravikant KumarversusThe State of Bihar

Decided: 20 January 2026
Disposal: BAIL GRANTED
Bench: PRABHAT KUMAR SINGH

Holding

The Court granted anticipatory bail to the petitioners subject to conditions under Section 482(2) of BNSS 2023.

Summary

The petitioners, Ravikant Kumar and Kiran Devi, sought anticipatory bail in a murder case where the informant's daughter was allegedly killed over dowry demands. They are the brother‑in‑law and mother‑in‑law of the deceased and claim they have no involvement, asserting that the accusations are general and omnibus. The State opposed the bail, arguing the seriousness of the offences under Sections 80(2) and 3(5) of the BNS. The Court, noting the petitioners' clean antecedents and lack of direct connection to the crime, ordered anticipatory bail on the condition that they surrender within eight weeks, furnish a bail bond of Rs 10,000 each with two sureties, and comply with Section 482(2) of the BNSS 2023. The order was made by Justice Prabhat Kumar Singh.

Issues considered

Whether anticipatory bail can be granted to the petitioners under Section 482(2) of BNSS 2023 despite the serious nature of the alleged offences.
Whether the petitioners' clean antecedent and lack of direct involvement justify the grant of bail.
Whether the allegations against the petitioners are sufficiently specific to deny bail.

Legislation cited

BNS — s. 3(5), 80(2)
BNSS, 2023 — s. 482(2)

Subjects

anticipatory bail
clean antecedent
dowry death
murder
Section 482
criminal procedure
over‑implication

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                                CRIMINAL MISCELLANEOUS No.55 of 2026
                      Arising Out of PS. Case No.-529 Year-2024 Thana- DHANARUA District- Patna
               ======================================================
           1 . Ravikant Kumar S/O Mahabir Prasad @ Mahavir Prasad @ Sahajanand @
                Sachitanand Prasad @ Sahajanand Prasad R/O Village-Milki Par Nanauri,
                P.S. Dhanarua, District-Patna
           2.    Kiran Devi W/O Mahabir Prasad @ Mahavir Prasad @ Sahajanand @
                 Sachitanand Prasad @ Sahajanand Prasad R/O Village-Milki Par Nanauri,
                 P.S. Dhanarua, District-Patna.

                                                                                  ... ... Petitioner/s
                                                        Versus
                 The State of Bihar

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :         Mr. Ravish Mishra, Advocate
                 For the Opposite Party/s :         Mr. Rabindra Kumar , APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE PRABHAT KUMAR SINGH
                                       ORAL ORDER

2   20-01-2026                                Heard learned counsel for the petitioners and

                   learned A.P.P. for the State.

                             2. The petitioners apprehend their arrest in a complaint

                   case punishable for the offence under Sections 80 ( 2 ) and and

                   3(5) of BNS.

                             3 . As per prosecution case , daughter of informant was

                   married to co-accused Harikant Kumar in the year 2024 and

                   after the marriage , she was subjected to cruelty and harassment

                   by all the accused persons due to non-fulfillment of demand of

                   dowry and ultimately the accused persons committed the murder

                   of informant’s daughter.

                            4. Petitioner no. 1 is brother-in -law ( Bhaisur ) and
            Patna High Court CR. MISC. No.55 of 2026(2) dt.20-01-2026
                                                        2/2




                      petitioner no. 2       mother-in -law is of the deceased. They are

                      simply victim of over implications. Allegation is general and

                      omnibus against these petitioners. Petitioners are separate in

                      mess and property and have got no concern with deceased and

                      her husband. Thrust of the accusation is against husband of the

                      deceased who is already in custody . Petitioners claim clean

                      antecedent.

                                   5. Learned A.P.P. for the State vehemently opposes the

                      prayer for anticipatory bail of petitioners.

                                   6. However, considering the aforesaid facts, clean

                      antecedent of these petitioners and other circumstances of the

                      case , let the above named petitioners, in the event of

                      arrest/surrender within a period of eight weeks from today, be

                      enlarged on bail on furnishing bail-bonds of Rs. 10,000/- (ten

                      thousand) each with two sureties of the like amount each to the

                      satisfaction of learned SDJM Masaurhi Patna in connection

                      with Dhanarua P.S. Case No. 529 of                2024 , subject to

                      condition as laid down under Section 482 ( 2 ) of BNSS 2023 .



                                             (Prabhat Kumar Singh, J)
Koushik/-

U      T

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