Patna High Court

Kamlesh SahniversusThe State of Bihar

Decided: 16 February 2026
Disposal: BAIL REJECTED
Bench: PRABHAT KUMAR SINGH

Holding

The court held that, given the specific and direct nature of the accusations and the gravity of the offences, bail could not be granted to the petitioner.

Summary

The petitioner, Kamlesh Sahni, sought bail in a case registered under Sections 120B, 201, 304B and 34 of the Indian Penal Code, alleging that he was falsely implicated in the dowry‑related murder of his wife. The prosecution alleged that the petitioner, along with other accused, tortured the victim for dowry and caused her death. The petitioner contended he had no role in the alleged offences and that the informant was not an eye‑witness. The State opposed bail, emphasizing the specific accusations, the seriousness of the offences and the petitioner’s position as the husband of the deceased. The court, after considering the gravity of the charges and the direct nature of the allegations, rejected the bail application and directed the trial court to expedite the trial within a year.

Issues considered

Whether the petitioner is entitled to bail despite the seriousness of the offences under Sections 120B, 201, 304B and 34 IPC
Whether the nature of the accusations and the petitioner’s relationship to the victim justify denial of bail

Legislation cited

Indian Penal Code — s. 120B, 201, 304B, 34

Subjects

bail
dowry death
criminal conspiracy
IPC
high court
pre‑trial detention

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                               CRIMINAL MISCELLANEOUS No.6280 of 2026

                 Arising Out of PS. Case No.-308 Year-2022 Thana- PAKRIDAYAL District- East Champaran
                 ======================================================
                 Kamlesh Sahni S/O Ramugrah Sahni @ Ramugar Sahni R/O Vill.-
                 Bhagwanpur, P.S.- Pakaridayal, Dist.- East Champaran, Bihar

                                                                                  ... ... Petitioner/s
                                                       Versus

                 The State of Bihar


                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner      :        Mr. Harishankar Raj, Advocate
                 For the State           :        Mr. Bharat Bhushan, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE PRABHAT KUMAR SINGH
                                       ORAL ORDER

2   16-02-2026                  Heard learned counsel for the petitioner and learned

                   A.P.P. for the State.

                                2. The petitioner seeks bail in a case registered for the

                   offence punishable under Sections 120B, 201, 304B and 34 of

                   the Indian Penal Code.

                                3. As per prosecution case, it is alleged that marriage

                   of daughter of informant was solemnized with this petitioner on

                   18.06.2018 as per Hindu rites and rituals. It is alleged that after

                   marriage, all the F.I.R. named accused persons, including this

                   petitioner, started torturing and harassing the victim due to non-

                   fulfillment of demand of dowry and subsequently, killed her.
Patna High Court CR. MISC. No.6280 of 2026(2) dt.16-02-2026
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                       4. Learned counsel for the petitioner submits that

          petitioner is quite innocent and has committed no offence.

          Informant is not an eye witness to the occurrence. Petitioner has

          falsely been implicated in this case merely because he happens

          to be husband of the deceased. At no point of time, petitioner

          tortured or harassed the victim or demanded dowry. Moreover,

          charge-sheet has already been submitted and petitioner is in

          custody since 09.10.2025.

                       5. On the other hand, learned A.P.P. for the State has

          vehemently opposed the prayer for grant of bail to the petitioner

          and submitted that petitioner is named in the F.I.R. with specific

          accusation of that he, along with other accused persons, killed

          the victim due to non-fulfillment of demand of dowry. Petitioner

          is husband of the deceased who died unnatural death at her

          matrimonial house within seven years of marriage.

                       6. Considering the facts and circumstances of the

          case, specific and direct nature of accusation and gravity of

          offence, the prayer for grant of bail to the petitioner is rejected.

                       7. However, considering the fact that petitioner is in

          custody since 09.10.2025, the learned trial court is directed to

          expedite the trial and conclude the same, preferably within a

          period of one year from the date of receipt/production of a copy
             Patna High Court CR. MISC. No.6280 of 2026(2) dt.16-02-2026
                                                         3/3




                       of this order.



                                             (Prabhat Kumar Singh, J)
shashank/-

U      T

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