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Patna High Court

Deep RatanversusThe State of Bihar

Decided
Disposal
BAIL GRANTED

Holding

Anticipatory bail is granted to the petitioner, subject to the stipulated conditions.

Summary

The petitioner, Deep Ratan, was implicated in a complaint (No. 10411 of 2023) alleging assault and torture of a woman for dowry, invoking Sections 498-A of the IPC and Section 4 of the Dowry Prohibition Act. He applied for anticipatory bail, asserting his innocence and claiming false implication. The State opposed the bail, but the Court, relying on the Supreme Court’s guidelines in Arnesh Kumar v. State of Bihar, granted anticipatory bail. The order required a bail bond of Rs.10,000 with two sureties and imposed a monthly maintenance payment of Rs.10,000 to the informant, subject to any future maintenance proceedings. The bail was conditioned under Section 438(2) of the CrPC and Section 482 of the BNSS.

Issues considered

  • Whether anticipatory bail should be granted to the petitioner under Section 438 CrPC in view of the allegations under Sections 498-A IPC and 4 Dowry Prohibition Act.
  • Whether the conditions imposed, including the maintenance payment, are lawful and appropriate.
  • Application of the Arnesh Kumar guidelines on arrest and bail.

Legislation cited

Subjects

  • anticipatory bail
  • Section 498-A IPC
  • Dowry Prohibition Act
  • Section 438 CrPC
  • maintenance order
  • Arnesh Kumar guidelines

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.60607 of 2025
                 Arising Out of PS. Case No.-10411 Year-2023 Thana- SAMASTIPUR COMPLAINT CASE
                                                   District- Samastipur
                 ======================================================
                 Deep Ratan Son of Sri NavRatan Prasad Sinha R/o Village - Registrar
                 Campus, Musapur Road, Sonvarsha, P.S. - Muffasil, District - Samastipur.

                                                                            ... ... Petitioner/s
                                                   Versus
           1.    The State of Bihar
           2.    Anumeha Verma D/o Ashok Kumar Verma at present residing at 301, Ashok
                 Vihar Apartment, Kasturva Path, North S.K. Puri, Boring Road, P.S. - S.K.
                 Puri, Dist. - Patna.

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :    Mr.Jyoti Kumari
                 For the Opposite Party/s :    Mr.Sharda Kumari
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE SANDEEP KUMAR
                                       ORAL ORDER

5   20-02-2026                       Heard learned counsel for the petitioner, learned

                   counsel for the Informant and learned APP for the State.

                                   2. The petitioner apprehends his arrest in

                   connection with Complaint Case No. 10411© of 2023 registered

                   for the offence under Sections 498-A of the Indian Penal Code

                   and under Section 4 of the Dowry Prohibition Act.

                                   3. As per the prosecution case, the petitioner is

                   accused of assaulting and torturing the victim for demand of

                   dowry.

                                   4. It has been submitted by the learned counsel for

                   the petitioner that the petitioner is innocent and he has falsely

                   been implicated in this case.
Patna High Court CR. MISC. No.60607 of 2025(5) dt.20-02-2026
                                            2/3




                          5. Learned counsel for the State has opposed the

          application of the petitioner.

                          6 . Considering the submission of the parties and in

          view of the law laid down by the Hon’ble Supreme Court in the

          case of Arnesh Kumar Vs. State of Bihar reported in (2014) 8

          SCC 273, this application of grant of anticipatory bail is

          allowed.

                          7. Let the petitioner, above named, in the event of

          his arrest or surrender before the concerned Court below within

          six weeks from today, be released on bail on furnishing bail

          bond of Rs. 10,000/- (Ten Thousand) with two sureties of the

          like amount each to the satisfaction of the learned Court of

          SDJM, Patna/concerned Court below in connection Complaint

          Case No. 10411© of 2023, subject to the conditions laid down

          in Section 438(2) of the Code of Criminal Procedure, 1973 /

          Section 482 of the BNSS.

                          8. As a condition of this order, the petitioner is

          directed to pay a maintenance amount of Rs. 10,000/- from the

          month of February, 2026 to the informant and the maintenance

          for the month of February, 2026 shall be paid to the informant

          within ten days of pronouncement of this order and thereafter

          the maintenance amount from the month of March, 2026 shall
          Patna High Court CR. MISC. No.60607 of 2025(5) dt.20-02-2026
                                                      3/3




                    be paid to the informant every month before the 10 th day of the

                    month.

                                    9. It is made clear that the aforesaid maintenance

                    order will be subject to the outcome of any order of concerned

                    Court below passed in maintenance proceedings, if any.



                                                              (Sandeep Kumar, J)
Vikas/-

U


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