Patna High Court

Ramani DeviversusThe State of Bihar

Decided: 13 February 2026
Disposal: BAIL GRANTED
Bench: SONI SHRIVASTAVA

Holding

The Court granted bail to the petitioner, finding no substantive material against her.

Summary

Ramani Devi, the daughter of a murder victim, was arrested as an accused under sections 103(1) and 61(2) of the B.N.S, 2023 in a case where she had also acted as the informant. She applied for bail, arguing that there is no eye‑witness, no substantive material linking her to the crime and that the accusation is based merely on suspicion and a possible conspiracy by enemies. The State opposed the bail. The Court noted that the petitioner is the informant, has no criminal antecedent, and that the charge‑sheet and case diary contain no cogent evidence against her. Consequently, the Court ordered that she be released on bail upon furnishing a bail bond of Rs.10,000 with two sureties. The bail order was made pending further trial in the successor court.

Issues considered

Whether bail should be granted to the petitioner accused under sections 103(1) and 61(2) of the B.N.S, 2023 in the absence of substantive evidence.
Whether the petitioner, being the informant and daughter of the deceased, can be considered a suspect based solely on suspicion.

Legislation cited

B.N.S., 2023 — s. 103(1), 61(2)

Subjects

bail
criminal procedure
suspicion
informant
murder
B.N.S 2023
sections 103
section 61
Bihar High Court

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.75131 of 2025
                        Arising Out of PS. Case No.-174 Year-2025 Thana- JHAJHA District- Jamui
                 ======================================================
                 Ramani Devi W/o Khiru Yadav R/o - Harna, P.S - Jhaja, District - Jamui
                                                                            ... ... Petitioner/s
                                                Versus
                 The State of Bihar
                                                                     ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :       Mr.Amar Prakash, Adv.
                 For the Opposite Party/s :       Mr.Pawan Kumar Chaurasia, APP
                 ======================================================
                 CORAM: HONOURABLE JUSTICE SMT. SONI SHRIVASTAVA
                                       ORAL ORDER

4   13-02-2026                     Heard learned counsel for the petitioner and learned

                   APP for the State.

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

                   petitioner in connection with Jhajha P.S. Case no.174 of 2025

                   registered under section 103(1) and 61(2) of B.N.S, 2023.

                                3. As per the prosecution case, the informant

                   (petitioner) states that while she was sleeping inside her house,

                   unknown person stabbed her mother during the night, as a result

                   of which she was found dead.

                                4. Learned counsel for the petitioner submits that this

                   is a peculiar case wherein the informant, who is the daughter of

                   the deceased, has herself been made an accused in the present

                   case and is the petitioner before this Court. It is further

                   submitted that there is no eye-witness to the alleged occurrence

                   and that the case has been lodged merely on suspicion. The

                   name of the petitioner surfaced during the course of

                   investigation, but only on the basis of suspicion. There is no
            Patna High Court CR. MISC. No.75131 of 2025(4) dt.13-02-2026
                                                        2/2




                      material on record to show the complicity of the petitioner in the

                      alleged crime. It is contended that the petitioner has been falsely

                      implicated as a result of a conspiracy hatched by her enemies.

                      The petitioner is in custody since 14.05.2025 and has no

                      criminal antecedent. She undertakes to cooperate in the

                      case/trial and charge-sheet has been submitted in the case.

                                   5. The application for bail is opposed by learned

                      A.P.P. for the State.

                                   6. Taking into consideration the aforesaid facts and

                      circumstances of the case and also considering the fact that the

                      petitioner herself is the informant of the case and also happens

                      to be the daughter of the deceased, coupled with the fact that no

                      substantive or cogent material against the petitioner appears in

                      the case diary and charge-sheet having been submitted in the

                      case, the petitioner is directed to be enlarged on bail in

                      connection with Jhajha P.S. Case no.174 of 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.


                                                (Soni Shrivastava, J)

Harsh/-
U       T

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