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Patna High Court

Sanjeela Khatoon @ Sanjida KhatoonversusThe State of Bihar

Decided
Disposal
BAIL GRANTED

Holding

The court held that, given the absence of evidence of a dowry demand, the suicide of the deceased, and the lack of imminent trial, bail should be granted to the petitioner.

Summary

The petitioner, Sanjeela Khatoon, mother‑in‑law of the deceased, sought bail in a case alleging that she and others killed the informant’s daughter over a dowry demand. The FIR alleged murder, but the petitioner contended that the marriage was a love marriage, there was no dowry demand, and the daughter died by suicide due to depression, as supported by the post‑mortem report indicating asphyxia from antemortem hanging. The petitioner had been in custody since 18‑08‑2025, had no prior criminal record, and the charges were only framed on 12‑02‑2026 with no witnesses examined. The State opposed bail, arguing the alleged dowry‑related murder. The court, noting the lack of evidence of dowry demand, the suicide finding, the petitioner’s clean record, and the likelihood of a prolonged trial, granted bail on a bond of Rs.10,000 with two sureties and directed the trial court to expedite the proceedings without unnecessary adjournments.

Issues considered

  • Whether bail should be granted to the petitioner under sections 61(2) and 80 of the BNS, 2023 in view of the alleged dowry‑related death.
  • Whether the facts indicate murder or suicide, affecting the bail consideration.
  • Whether the petitioner is likely to flee or tamper with evidence.
  • Whether the trial is likely to conclude soon, justifying bail.

Legislation cited

Subjects

  • bail
  • dowry death
  • love marriage
  • suicide
  • criminal procedure
  • BNS 2023
  • section 61(2)
  • section 80
  • expedited trial

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.75110 of 2025
                      Arising Out of PS. Case No.-234 Year-2025 Thana- KARJA District- Muzaffarpur
                 ======================================================
                 Sanjeela Khatoon @ Sanjida Khatoon W/o Md. Reyaz@Md. Reyaz Ahmad
                 R/o Village - Mansurpur Chamarua, P.S - Karja, District - Muzaffarpur

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s       :      Mr.Sanjay Kumar, Adv.
                 For the State              :      Mr. Ram Priya Sharan Singh, APP
                 For the Informant          :      Mr. Ganesh Prasad Singh, Adv.
                 ======================================================
                 CORAM: HONOURABLE JUSTICE SMT. SONI SHRIVASTAVA
                                       ORAL ORDER

3   13-02-2026                          Heard learned counsel for the petitioner, learned

                   APP for the State and learned counsel for the informant.

                                   2. A prayer for bail has been made on behalf of the

                   petitioner in connection with Karja P.S. Case no.234 of 2025

                   registered under sections 61(2) and 80 of BNS, 2023.

                                 3. Allegation in the F.I.R is that the petitioner along

                   with others killed the informant’s daughter on account of non-

                   fulfillment of demand of dowry.

                                 4. Learned counsel for the petitioner submits that

                   petitioner is the mother-in-law of the deceased and the F.I.R

                   discloses clearly that love marriage had taken place between the

                   deceased and her husband i.e. the son of the petitioner. It has

                   further been submitted that there is no question of demand of
Patna High Court CR. MISC. No.75110 of 2025(3) dt.13-02-2026
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          dowry in a case where love marriage had been performed. It is

          only on account of matrimonial discord that the deceased

          committed suicide owing to depression and mental anxiety and

          the post-mortem report of the deceased is also supportive of the

          said fact that the deceased had died due to asphyxia as a result

          of antemortem hanging. The petitioner is in custody since

          18.08.2025 and has no criminal antecedent. She undertakes to

          cooperate in the case/trial. Charges have already been framed on

          12.02.2026.

                       5. The application for bail is opposed by learned

          A.P.P. for the State as also learned counsel for the informant on

          the ground that informant’s daughter was killed by the petitioner

          along with others on nonfulfillment of demand of dowry within

          a year of marriage.

                       6. Taking into consideration the aforesaid facts and

          circumstances of the case and also considering that petitioner is

          the mother-in-law of the deceased and the marriage between the

          deceased and her husband was a love marriage coupled with the

          fact that charges have been framed on 12.02.2026 and till date

          no witness has been examined and there is no likelihood to

          conclude the trial in the near future, the petitioner is directed to

          be enlarged on bail in connection with Karja P.S. Case no.234 of
              Patna High Court CR. MISC. No.75110 of 2025(3) dt.13-02-2026
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                        2025 on furnishing bail bond of                  Rs.10,000/- (Rupees Ten

                        Thousand) with two sureties of the like amount each to the

                        satisfaction of the learned Court concerned where the case is

                        pending/successor Court, subject to the further condition that

                        petitioner shall remain physically present in the learned trial

                        Court on each date and shall cooperate in the trial. In case the

                        petitioner is absent on the two consecutive dates without

                        sufficient reasons, the learned trial Court would be at liberty to

                        cancel the bail bonds of the petitioner.

                                     7. The trial Court is directed to expedite the trial

                        without giving any unnecessary adjournment.


                                                  (Soni Shrivastava, J)

Harsh/-

U         T


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