Patna High Court

Sanjip Kumar @ Sanjeev KumarversusThe State of Bihar

Decided: 4 February 2026
Disposal: BAIL GRANTED
Bench: R P MISHRA

Holding

The court granted anticipatory bail to the petitioner subject to bond and surety conditions under Section 482(2) of the Bharatiya Nagarik Suraksha Sanhita, 2023.

Summary

The petitioner, Sanjip Kumar, sought anticipatory bail fearing arrest in a dowry‑death case (Minapur P.S. Case No. 195 of 2025) registered under Sections 80 and 3(5) of the Bharatiya Nyaya Sanhita, 2023. The prosecution alleged that the petitioner, along with family members, tortured and killed the informant’s sister for dowry demands. The petitioner contended that he is innocent, is the brother‑in‑law of the deceased, has no criminal antecedent, and that the allegations against him are vague and omnibus. He also highlighted that a co‑accused had been granted regular bail in a related matter. The State opposed the bail, arguing the seriousness of the charges. Considering the facts, the court granted anticipatory bail subject to a bond of Rs. 15,000 with two sureties and conditions under Section 482(2) of the Bharatiya Nagarik Suraksha Sanhita, 2023.

Issues considered

Whether anticipatory bail can be granted under Section 482(2) of the Bharatiya Nagarik Suraksha Sanhita, 2023 in the present case
Whether the allegations against the petitioner are specific enough to deny bail
Whether the petitioner’s lack of criminal antecedent and the grant of bail to a co‑accused warrant anticipatory bail

Legislation cited

Bharatiya Nagarik Suraksha Sanhita, 2023 — s. 482(2)
Bharatiya Nyaya Sanhita, 2023 — s. 3(5), 80

Subjects

anticipatory bail
dowry death
Section 80
Section 3(5)
Section 482(2)
Bharatiya Nyaya Sanhita
Bharatiya Nagarik Suraksha Sanhita
criminal procedure
bail conditions

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.7151 of 2026
                    Arising Out of PS. Case No.-195 Year-2025 Thana- MINAPUR District- Muzaffarpur
                 ======================================================
                 Sanjip Kumar @ Sanjeev Kumar son of Ravan Sahani @ Ramnandan Sahani
                 Resident of Village- Bara Bharti, P.S.- Minapur, Dist- Muzaffarpur

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :       Mr. Saurav Anand, Advocate
                 For the Opposite Party/s :       Mrs. Nirmala Kumari, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE RUDRA PRAKASH
                 MISHRA
                                       ORAL ORDER

2   04-02-2026                    Heard learned counsel for the petitioner and learned

                   APP for the State.

                                2. The petitioner apprehends arrest in connection with

                   Minapur P.S. Case No. 195 of 2025, registered under Sections

                   80 and 3(5) of the Bharatiya Nyaya Sanhita, 2023.

                                3. The prosecution case, in short, is that the petitioner

                   along with the family members tortured and killed the sister of

                   the informant for non-fulfillment of demand of dowry.

                                4. Learned counsel for the petitioner submits that the

                   petitioner is innocent and has falsely been implicated in the

                   present case. Learned counsel for the petitioner also submitted

                   that the petitioner is brother-in-law of deceased. Husband of the

                   deceased is in custody. No specific allegation has been
             Patna High Court CR. MISC. No.7151 of 2026(2) dt.04-02-2026
                                                         2/2




                       attributed against the petitioner rather the same is general and

                       omnibus in nature. It is next submitted that the petitioner is

                       separate in mess and business from the husband of the deceased.

                       The petitioner has got no criminal antecedent. Learned counsel

                       for the petitioner further submits that other co-accused has been

                       granted regular bail by this Court vide order dated 25.09.2025

                       passed in Cr. Misc. No. 68897 of 2025.

                                    5. Learned APP for the State has vehemently opposed

                       the prayer for grant of bail to the petitioner.

                                    6. Considering the aforesaid facts and circumstances,

                       let the petitioner, above named in the event of arrest/surrender

                       before the learned Court below within a period of six weeks

                       from today, be released on anticipatory bail on furnishing bail

                       bonds of Rs. 15,000/- (Rupees Fifteen Thousand) with two

                       sureties of the like amount each to the satisfaction of Court

                       below/concerned Court in connection with Minapur P.S. Case

                       No. 195 of 2025, subject to the conditions as laid down under

                       Section 482(2) of the Bharatiya Nagarik Suraksha Sanhita,

                       2023.



                                                                    (Rudra Prakash Mishra, J)
Rajorshi/-

U       T

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