Patna High Court

Sanjay Kumar Singh @ Sanjay SinghversusThe State of Bihar

Decided: 9 April 2026
Disposal: BAIL GRANTED
Bench: PRAVEEN KUMAR

Holding

The Court granted bail to the petitioner.

Summary

The petitioner, Sanjay Kumar Singh, applied for regular bail in a case registered under Section 103(1) of the B.N.S., alleging he was falsely implicated in the death of his wife, Puja Kumari, who allegedly died from hanging. The prosecution alleged that the petitioner and others tortured the deceased over dowry demands, leading to her death. The petitioner argued that the post‑mortem showed no injuries and the cause of death was asphyxia due to hanging, that he has no prior criminal record, and that he has been in custody since 6 May 2025. The State opposed the bail, contending the seriousness of the offence. After considering the submissions and circumstances, the Court ordered that the petitioner be released on bail upon furnishing a bail bond of Rs.10,000 with two sureties, and the application was allowed.

Issues considered

Whether bail should be granted to the petitioner under Section 103(1) of the B.N.S. in view of the alleged dowry‑related death and the circumstances of the case

Legislation cited

B.N.S. — s. 103(1)

Subjects

bail
dowry death
Section 103
false implication
criminal procedure
post‑mortem report

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.7333 of 2026
                     Arising Out of PS. Case No.-122 Year-2025 Thana- AWTARNAGAR District- Saran
                 ======================================================
                 Sanjay Kumar Singh @ Sanjay Singh S/o Late Lal Bahadur Singh R/o Vill-
                 Pratappur, P.O. and P.S- Atwatarnagar, Dist- Saran at Chapra-841301

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :      Mr. Jeetendra Narayan, Advocate
                 For the Opposite Party/s :      Mr. Jitendra Kumar Singh, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE PRAVEEN KUMAR
                                       ORAL ORDER

4   09-04-2026                  Heard learned counsel for the petitioner and learned

                   APP for the State.

                                2. The petitioner has preferred this application for

                   grant of regular bail in connection with Sessions Trial No. 1017

                   of 2025 (arising out of Awtarnagar P.S. Case No. 122 of 2025)

                   registered for the offences punishable under Sections 103(1) of

                   the B.N.S.

                                3. As per the prosecution case, the marriage of the

                   informant’s daughter, namely, Puja Kumari was solemnized

                   with the petitioner on 24.04.2017. It is further alleged that after

                   few months of marriage, all the accused persons started

                   torturing her mentally and physically due to non-fulfillment of

                   demand of dowry and two children were born out of their

                   wedlock. On 09.04.2025, the petitioner took the daughter of the
Patna High Court CR. MISC. No.7333 of 2026(4) dt.09-04-2026
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          informant back to his home, promising to keep her with respect

          and look after her properly. Subsequently, on 04.05.2025, the

          informant got information that his daughter has been done to

          death for non-fulfillment of demand of dowry.

                       4. Learned counsel for the petitioner has submitted

          that the petitioner happens to be the husband of the deceased,

          has falsely been implicated in this case. The case has been

          registered under Section 103 of the BNS. The postmortem

          report indicates that there were no external or internal injuries

          on the body of the deceased, and the cause of death has been

          opined due to asphyxia as a result of hanging. It has further been

          submitted that the charge sheet has already been filed against

          the petitioner and he undertakes to co-operate in the trial. Out

          of the wedlock, two children were born, who are presently

          living without proper care. Lastly, it has been submitted that the

          petitioner has clean criminal antecedent and is in custody since

          06.05.2025.

                       5. Learned APP for the State has vehemently opposed

          the prayer for bail of the petitioner.

                       6. Considering the aforesaid submissions of the

          parties and taking into account the facts and circumstance of the

          case, let the petitioner above-named, be enlarged on bail on
          Patna High Court CR. MISC. No.7333 of 2026(4) dt.09-04-2026
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                    furnishing bail-bonds of Rs. 10,000/- (Rupees Ten Thousand)

                    with two sureties of the like amount each to the satisfaction of

                    learned Court concerned, Saran, in connection with Sessions

                    Trial No. 1017 of 2025 (arising out of Awtarnagar P.S. Case No.

                    122 of 2025).

                                 7. The application stands allowed.



                                               (Praveen Kumar, J)
Jyoti/-

U

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