Patna High Court
Prem Lal SahniversusThe State of Bihar
- Decided
- Disposal
- BAIL GRANTED
- Bench
- NAWNEET KUMAR PANDEY
Holding
The court granted regular bail to the petitioner, directing him to furnish a bail bond of Rs. 10,000 with two sureties.
Summary
The petitioner, Prem Lal Sahni, father‑in‑law of the deceased, was implicated in a murder‑dowry case (Sakra P.S. Case No. 138 of 2025) under Sections 80 and 3(5) of the B.N.S. He sought regular bail, claiming innocence and that he was framed merely because of his familial relationship. The prosecution alleged that the deceased and her baby were killed and hanged, and that the husband had assaulted her after a dispute over dowry. The defense argued there was no direct involvement of the petitioner and that the FIR indicated the husband’s misconduct, not the petitioner’s. The court, after considering the submissions, ordered the release of the petitioner on bail upon furnishing a bond of Rs. 10,000 with two sureties, directing compliance with the Judicial Magistrate‑I of Muzaffarpur.
Issues considered
- Whether the petitioner is entitled to regular bail in a murder‑dowry case under Sections 80 and 3(5) of the B.N.S.
Legislation cited
- B.N.S. — s. 3(5), 80
Subjects
- bail
- regular bail
- murder
- dowry death
- Section 80
- Section 3(5)
- father‑in‑law
- criminal procedure
Judgment
IN THE HIGH COURT OF JUDICATURE AT PATNA
CRIMINAL MISCELLANEOUS No.64921 of 2025
Arising Out of PS. Case No.-138 Year-2025 Thana- SAKRA District- Muzaffarpur
======================================================
Prem Lal Sahni S/O Parikshan Sahni R/O Vill.- Simra, P.S.- Sakra, Dist.-
Muzaffarpur.
... ... Petitioner/s
Versus
The State of Bihar Patna
... ... Opposite Party/s
======================================================
Appearance :
For the Petitioner/s : Mr.Ravi Ranjan
For the Opposite Party/s : Mr.Jitendra Kumar Singh
======================================================
CORAM: HONOURABLE MR. JUSTICE NAWNEET KUMAR
PANDEY
ORAL ORDER
4 21-01-2026 Heard learned counsel for the petitioner and learned APP
for the State.
2. The petitioner seeks regular bail in connection with
Sakra P.S. Case No. 138 of 2025 registered for the offence
punishable under Sections-80, 3(5) of B.N.S.
3. The prosecution case in brief is that the accused persons
including the petitioner (father-in-law) caused death of Rina Devi
and her baby and hanged her in Mahmmadpur Kothi Pilkhi Lichi
Gachhi by her sari. It is further alleged in the FIR that soon after her
marriage, she was subjected to cruelty and harassment in connection
with demand of dowry.
4. Learned counsel for the petitioner has submitted that
the petitioner is innocent and he has falsely been implicated in this
case. He is father-in-law of the deceased having no concern with the
Patna High Court CR. MISC. No.64921 of 2025(4) dt.21-01-2026
2/2
alleged occurrence. The petitioner has been made accused in this case
merely because he is father of husband of the deceased. The FIR
itself shows that the deceased saw her husband making physical
relation with his Bhabhi and on protest, he assaulted the deceased.
5. On the other hand, learned counsel for the informant
opposed the prayer for bail by submitting that all the accused persons
committed murder of the deceased and her baby.
6. There is allegation on the husband that he had physical
relation with his Bhabhi which was seen by the deceased due to
which, he badly assaulted his wife (deceased). The petitioner is
father-in-law and according to submission, the petitioner has been
made accused merely because he is father of husband of the
deceased.
7. Considering the aforesaid facts and circumstances, let
the petitioner named above, 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 learned Judicial Magistrate-Ist
Class, Muzaffarpur in connection with Sakra P.S. Case No. 138 of
2025.
(Nawneet Kumar Pandey, J)
A.K.V.//-
U T
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