Patna High Court
Chhotu Manjhi @ Chhotu KumarversusThe State of Bihar
- Decided
- Disposal
- BAIL GRANTED
- Bench
- KHATIM REZA
Holding
Bail was granted to the petitioner.
Summary
Chhotu Manjhi, husband of a woman who died under suspicious circumstances, was charged under Sections 103(1) and 3(5) of the Bharatiya Nyaya Sanhita, 2023 for murder. The informant, the deceased's father, alleged that the petitioner was responsible for his daughter's death. The petitioner sought bail, contending that the inquest report indicated suicide, there were no external injuries, and a forensic report suggested partial hanging; he was not present at the time of death and had taken the deceased to hospital. The court examined the forensic and inquest findings, the petitioner’s clean antecedents, and the fact that he was in custody since 12‑04‑2025. Considering the circumstances, the court granted bail on a bond of Rs.10,000 with two sureties, allowing the petitioner’s release.
Issues considered
- Whether bail should be granted to the accused in a murder case where the inquest and forensic reports suggest possible suicide.
- Whether the petitioner’s clean antecedents and lack of direct involvement at the time of death warrant bail.
Legislation cited
- Bharatiya Nyaya Sanhita, 2023 — s. 103(1), 108, 3(5)
Subjects
- bail
- murder
- suicide
- criminal procedure
- Bharatiya Nyaya Sanhita
- inquest report
- forensic evidence
Judgment
IN THE HIGH COURT OF JUDICATURE AT PATNA
CRIMINAL MISCELLANEOUS No.71071 of 2025
Arising Out of PS. Case No.-254 Year-2025 Thana- FATEHPUR District- Gaya
======================================================
Chhotu Manjhi @ Chhotu Kumar, aged about 27 years, Male, son of Durjan
Manjhi, resident of Village- Samda, P.S- Fatehpur, District- Gaya.
... ... Petitioner/s
Versus
The State of Bihar
... ... Opposite Party/s
======================================================
Appearance :
For the Petitioner/s : Mr. Bachanjee Ojha, Advocate
Mr. Brijmohan Das, Advocate
For the Opposite Party/s : Mr. Tarun Prasad Mandal, APP
For the Informant : Mr. Syed Asghar Najmi, Advocate
Ms. Wajeeha Jafee, Advocate
Mr. Ashutosh Kumar Mishra, Advocate
======================================================
CORAM: HONOURABLE MR. JUSTICE KHATIM REZA
ORAL ORDER
4 21-01-2026 Heard learned counsel for the petitioner; learned
Additional Public Prosecutor for the State and learned counsel
for the informant, who has appeared suo motu.
2. The petitioner seeks bail in connection with
Fatehpur PS Case No.254 of 2025 dated 11.04.2025, instituted
for the offence punishable under Sections 103(1), 3(5) of the
Bharatiya Nyaya Sanhita, 2023.
3. The informant has alleged that his daughter was
married with the petitioner about eight years ago. On
11.04.2025, the informant came to know that his daughter has
been killed by her in-laws. Petitioner is the husband of the
deceased.
Patna High Court CR. MISC. No.71071 of 2025(4) dt.21-01-2026
2/3
4. Learned counsel for the petitioner submits that it is
admitted fact that the marriage of the petitioner was performed
with the deceased about eight years ago and in the aforesaid
background, the Investigating Officer has submitted charge-
sheet under Section 108 of the Bharatiya Nyaya Sanhita, 2023.
It is further submitted that from the perusal of Inquest Report, it
would appear that it was a case of suicide and there was no sign
of any external injury on the person of the deceased. At the time
of occurrence, the petitioner was not present in the house and
when he came home and knew about the incident, he
immediately took the deceased to hospital and got her admitted
on 10.02.2025 at 12.30 PM; the deceased was kept on ventilator
for one day and the deceased died on 11.10.2025 at 12.20 PM.
Learned counsel further submitted that in the report of Forensic
Science Laboratory, it is clearly mentioned that partial hanging
may be possible on the basis of inspection of the crime scene.
The deceased herself committed suicide in absence of the
petitioner. Lastly, it is submitted that the petitioner is in custody
since 12.04.2025 having clean antecedents.
5. Learned APP as well as learned counsel for the
informant has opposed the prayer for bail. Learned counsel for
the informant submits that the petitioner is the husband of the
Patna High Court CR. MISC. No.71071 of 2025(4) dt.21-01-2026
3/3
deceased and he is wholly responsible towards the deceased.
6. Having considered the facts and circumstances of
the case and submissions of learned counsel for the parties, let
the petitioner be released on bail upon furnishing bail bonds of
Rs. 10,000/- (ten thousand) with two sureties of the like amount
each to the satisfaction of the CJM, Gaya, in Fatehpur PS Case
No.254 of 2025.
7. The application stands allowed.
(Khatim Reza, J)
J. Alam/-
U T
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