Patna High Court

Achhelal PatelversusThe State of Bihar

Decided: 11 February 2026
Disposal: BAIL GRANTED
Bench: PRABHAT KUMAR SINGH

Holding

Anticipatory bail was granted to the petitioner.

Summary

The petitioner, Achhelal Patel, father‑in‑law of the deceased, was implicated in a dowry‑harassment and murder case registered under Sections 80(2), 238 and 3(5) of the Bharatiya Nyaya Sanhita. The prosecution alleged that after the marriage of his daughter‑in‑law, the accused, including the petitioner, tortured the victim for dowry and eventually murdered her. The petitioner contended that he had no involvement, maintained a separate property, and was merely a victim of over‑implication, especially since the husband of the deceased was already in custody. He applied for anticipatory bail fearing arrest. The State opposed the bail, but the court noted the husband’s custody and the lack of specific evidence against the petitioner. Consequently, the court granted anticipatory bail subject to a bond and sureties under Section 482(2) of the BNSS.

Issues considered

Whether anticipatory bail should be granted to the petitioner under Section 482(2) of the Bharatiya Nyaya Sanhita given the circumstances of the case.

Legislation cited

Bharatiya Nyaya Sanhita — s. 238, 3(5), 482(2), 80(2)

Subjects

anticipatory bail
dowry harassment
murder
Bharatiya Nyaya Sanhita
Section 482
over‑implication
criminal procedure

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.6650 of 2026
                  Arising Out of PS. Case No.-527 Year-2025 Thana- MUFFASIL District- West Champaran
                 ======================================================
                 Achhelal Patel Son of Nand Lal Patel Resident of Village- Sheikhauna, P.S.-
                 Bettiah (Muffasil), District- West Champaran

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :       Mr. Sanjeev Kumar Shrivastava, Advocate
                 For the Opposite Party/s :       Mr. Awadhesh Kumar Singh, A.P.P.
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE PRABHAT KUMAR SINGH
                                       ORAL ORDER

2   11-02-2026                    Heard learned counsel for the petitioner and learned

                   A.P.P. for the State.

                                2. Petitioner apprehends arrest in a case registered for

                   the offences punishable under Sections 80(2), 238, 3(5) of the

                   Bharatiya Nyaya Sanhita.

                                3. As per prosecution case, informant alleged that

                   marriage of his daughter was solemnized with co-accused Raj

                   Kumar on 30.04.2025 as per Hindu rites and rituals and

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

                   petitioner, committed torture and harassment with the victim

                   due to non-fulfillment of demand of dowry and subsequently, all

                   the accused persons committed murder of the victim.

                                4. Learned counsel for the petitioner submits that

                   petitioner is innocent and has committed no offence. Petitioner
            Patna High Court CR. MISC. No.6650 of 2026(2) dt.11-02-2026
                                                        2/2




                      is maternal father-in-law of the deceased and he is simply victim

                      of over-implication. Allegation against petitioner is general and

                      omnibus. Petitioner is separate in mess and property and has got

                      no concern with family affairs of the deceased. He further

                      submits that thrust of accusation is against husband of the

                      deceased who is already in custody since 30.10.2025. Petitioner

                      claims clean antecedent.

                                   5. Learned A.P.P. for the State vehemently opposed

                      the bail application.

                                   6. Considering the fact that husband of the deceased

                      in already in custody, this anticipatory bail is allowed and it is

                      ordered that let the above named petitioner in the event of his

                      arrest/surrender before the court below within a period of eight

                      weeks from today, be enlarged on bail on furnishing bail-bond

                      of Rs. 10,000/- (ten thousand) with two sureties of the like

                      amount each to the satisfaction of Chief Judicial Magistrate,

                      Bettiah, West Champaran in connection with Bettiah (Muffasil)

                      P. S. Case No. 527 of 2025, subject to condition as laid down

                      under Section 482 (2) of the BNSS.



                                            (Prabhat Kumar Singh, J)
Navya/-
U       T

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