Patna High Court

MANISH THAKURversusThe State of Bihar

Decided: 4 February 2026
Disposal: BAIL GRANTED
Bench: PRABHAT KUMAR SINGH

Holding

The Court granted anticipatory bail to the petitioners subject to the stipulated conditions.

Summary

The petitioners, who are relatives of a woman who died under alleged dowry harassment, feared arrest in a case registered under Section 80(2) and 3(5) of the B.N.S. The prosecution alleges that the deceased was killed on 12 July 2025 after being subjected to cruelty for dowry, while the petitioners claim they have no involvement and the accusations are general and omnibus. The State opposed their request for anticipatory bail. The Court examined the nature of the allegations and the petitioners' lack of direct connection to the alleged offence. It held that anticipatory bail could be granted, subject to conditions, to prevent undue hardship. Accordingly, the petitioners were ordered to furnish bail bonds of Rs.10,000 each with two sureties, within eight weeks, under Section 482 of the B.N.S.S., 2023.

Issues considered

Whether the petitioners can be arrested in the dowry death case under Section 80(2) and 3(5) of the B.N.S.
Whether anticipatory bail is appropriate in the circumstances of a general and omnibus allegation
Whether the conditions imposed under Section 482 of the B.N.S.S., 2023 are sufficient to safeguard the investigation

Legislation cited

B.N.S. — s. 3(5), 80(2)
B.N.S.S., 2023 — s. 482

Subjects

dowry death
anticipatory bail
Section 80
Section 482
general and omnibus allegation
family relations
criminal procedure

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.5551 of 2026
                  Arising Out of PS. Case No.-706 Year-2025 Thana- SIKARPUR District- West Champaran
                 ======================================================
           1.     Manish Thakur S/o Devnarayan Thakur @ Deo Narayan Thakur @
                  Denonath Thakur R/o vill - Mathur, P.S.- Shikarpur, Distt.- West Champaran
           2.    Asha Devi @ Aasha Devi W/o Manish Thakur R/o vill - Mathur, P.S.-
                 Shikarpur, Distt.- West Champaran
           3.    Girija Devi @ Gariji Devi W/o Devnarayan Thakur @ Deo Naryan Thakur
                 @ Denonath Thakur R/o vill - Mathur, P.S.- Shikarpur, Distt.- West
                 Champaran
           4.    Suraj Kumar @ Suraj Thakur S/o Devnarayan Thakur @ Deo Narayan
                 Thakur @ Denonath Thakur R/o vill - Mathur, P.S.- Shikarpur, Distt.- West
                 Champaran

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :       Mr.Sarvesh Kashyap
                 For the Opposite Party/s :       Mr.Ram Anurag Singh
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE PRABHAT KUMAR SINGH
                                       ORAL ORDER

2   04-02-2026                    Heard learned counsel for the petitioners and learned

                   A.P.P. for the State.

                                2. The petitioners apprehend their arrest in a case,

                   registered for the offence under Section 80(2), 3(5) of the

                   B.N.S.

                                3. As per prosecution case, daughter of informant was

                   married with co-accused Rajnish Thakur three years ago and

                   after the marriage, she was subjected to cruelty and harassment

                   by the accused persons for dowry and ultimately, on 12.07.2025,

                   she was killed.
           Patna High Court CR. MISC. No.5551 of 2026(2) dt.04-02-2026
                                                       2/2




                                  4. Petitioner no. 1 is brother-in-law (tsB), petitioner

                     no. 2 is sister-in-law (xksruh), petitioner no. 3 is mother-in-law

                     (lkl) and petitioner no. 4 is brother-in-law (nsoj) of the deceased.

                     There is general and omnibus allegation. Thrust of the

                     accusation is against husband of the deceased, who is already in

                     custody. As a matter of fact, the deceased committed suicide by

                     hanging. Petitioners are separate in mess and property and have

                     got no concern with the family affairs of deceased and her

                     husband.

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

                     anticipatory bail of petitioners.

                                  6. In the facts and 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 A.C.J.M. - 6th, Bettiah, West Champaran in connection

                     with Shikarpur P.S. Case No. 706 of 2025, subject to condition

                     as laid down under Section 482 of the B.N.S.S., 2023.



                                                     (Prabhat Kumar Singh, J)
anay

U      T

Continue reading with your account

Checking your session…