Patna High Court

Praveen Kumar @ RockyversusThe State of Bihar

Decided: 21 January 2026
Disposal: BAIL GRANTED
Bench: NAWNEET KUMAR PANDEY

Holding

The Court granted regular bail to the petitioner subject to bond and surety conditions.

Summary

Petitioner Praveen Kumar (Rocky) was arrested in connection with a dowry‑death case (Biharsharif P.S. Case No. 293 of 2025) under Sections 80(2) and 3(5) of the Bihar Negotiable Statutes (BNS). The informant alleged that the petitioner and his family demanded dowry and caused the death of his wife within 14 days of marriage. The petitioner contended that the FIR does not allege any dowry demand against him and that he merely informed the family of the death, claiming false implication. The State opposed bail, citing the seriousness of the offence. The Court, after considering the facts and the lack of direct allegation against the petitioner, granted regular bail on condition of a Rs.10,000 bond with two sureties and compliance with attendance requirements.

Issues considered

Whether bail should be granted to the accused in a dowry‑death case under Sections 80(2) and 3(5) of the BNS.
Whether the FIR’s omission of a direct dowry‑demand allegation against the petitioner warrants denial of bail.

Legislation cited

Bihar Negotiable Statutes (BNS) — s. 3(5), 80(2)

Subjects

bail
dowry death
Section 80(2) BNS
Section 3(5) BNS
criminal procedure
Bihar

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.65345 of 2025
                        Arising Out of PS. Case No.-293 Year-2025 Thana- BIHAR District- Nalanda
                 ======================================================
                 Praveen Kumar @ Rocky S/o- Jungbahadur Prasad R/o- Bajrachak Ps- Katri
                 Sarai Nalanda
                                                                        ... ... Petitioner/s
                                               Versus
                 The State of Bihar Bihar
                                                                 ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :        Mr.Ranjan Kumar Srivastava
                 For the Opposite Party/s :        Mr.Parmanand Kumar
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE NAWNEET KUMAR
                 PANDEY
                                       ORAL ORDER

4   21-01-2026                         Heard learned counsel for the petitioner as well as

                   learned APP for the State.

                                   2. In this case, the petitioner is seeking regular bail in

                   connection with Biharsharif P.S. Case No. 293 of 2025, registered for

                   the offences punishable under Sections 80(2) and 3(5) of BNS.

                                   3. The informant alleges that his daughter Premlata

                   Sinha got married with the petitioner on 30.04.2025 and lived with

                   him in a rented house at Biharsharif. On 14.05.2025, the petitioner

                   informed the informant about her death. It is alleged that due to

                   dowry demands and atrocities inflicted by the petitioner and his

                   family members, her death was caused within 14 days of her

                   marriage.

                                 4. The learned counsel for the petitioner has submitted

                   that the petitioner is innocent and has falsely been implicated.

                   Though the petitioner is husband of the deceased but the FIR itself

                   shows that there is no allegation of demand of dowry or torture

                   against the petitioner. That allegation is against Swaraj Babu,
           Patna High Court CR. MISC. No.65345 of 2025(4) dt.21-01-2026
                                                       2/2




                     Jungbahadur Prasad, Sila Devi, Kranti Devi and Amresh Prasad. The

                     petitioner is the person who informed the family members of the

                     deceased when she committed suicide. The petitioner is under

                     custody since 15.05.2025.

                                   5. On the other hand, the learned APP for the State has

                     opposed the prayer for bail.

                                  6.    Considering       the    above-mentioned   facts   and

                     circumstances, let the petitioner above-named be released on bail on

                     furnishing bail bonds of Rs.10,000/- with two sureties of the like

                     amount each to the satisfaction of learned Chief Judicial Magistrate,

                     Nalanda at Biharsharif in connection with Biharsharif P.S. Case No.

                     293 of 2025, subject to the condition that the petitioner shall

                     cooperate in the disposal of trial and make himself available as and

                     when required by the court.

                                  7. The petitioner shall physically appear before the

                     learned court below on each and every date. In case of failure on

                     two consecutive dates, unless he is prevented by extremely

                     adverse circumstances, the learned court below will be at liberty

                     to cancel the bail bonds of the petitioner.


                                          (Nawneet Kumar Pandey, J)

kundan/-
U      T

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