Patna High Court

Vinod YadavversusThe State of Bihar

Decided: 31 March 2026
Disposal: BAIL GRANTED
Bench: PRABHAT KUMAR SINGH

Holding

The court granted anticipatory bail to the petitioner, subject to a bail bond and sureties, under Section 482(2) of the Bharatiya Nyaya Sanhita.

Summary

The petitioner, Vinod Yadav, father‑in‑law of a deceased woman, was implicated in a dowry‑death case under Sections 80, 85 and 3(5) of the Bharatiya Nyaya Sanhita. He applied for anticipatory bail, asserting his innocence, clean antecedents and that the primary accused – the husband – was already in custody. The informant, the deceased’s father, opposed the bail. The court examined whether the allegations against the petitioner warranted denial of bail and considered the scope of Section 482(2) of the BNSS. Finding the accusations to be general and the petitioner to be a victim of over‑implication, the court allowed anticipatory bail with a bond of Rs 10,000 and two sureties, subject to conditions. The order was pronounced by Justice Prabhat Kumar Singh.

Issues considered

Whether anticipatory bail can be granted to the petitioner under Section 482(2) of the Bharatiya Nyaya Sanhita in a dowry‑death case.
Whether the allegations against the petitioner constitute sufficient ground to deny bail.

Legislation cited

Bharatiya Nyaya Sanhita — s. 3(5), 482(2), 80, 85

Subjects

dowry death
anticipatory bail
Bharatiya Nyaya Sanhita
Section 80
Section 85
Section 3(5)
Section 482(2)
criminal procedure
over‑implication

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.78337 of 2025
                      Arising Out of PS. Case No.-63 Year-2025 Thana- PAUTHU District- Aurangabad
                 ======================================================
                 Vinod Yadav S/O Sitaram Yadav R/O Village- Rampur, P.S- Pauthu, Distt.-
                 Aurangabad (Bihar).
                                                                       ... ... Petitioner/s
                                                Versus
                 The State of Bihar
                                                                ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :       Mr. Krishna Pd. Singh, Sr. Advocate
                                                  Mr. Rakesh Singh, Advocate
                 For the Opposite Party/s :       Mr. Anil Kumar Singh No. 1, A.P.P.
                 For the Informant        :       Mr. Arvind Kumar Singh, Advocate
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE PRABHAT KUMAR SINGH
                                       ORAL ORDER

3   31-03-2026                     Heard learned counsel for the petitioner, informant

                   and learned A.P.P. for the State.

                                 2. Petitioner apprehends arrest in a case registered for

                   the offences punishable under Sections 80, 85, 3(5) of the

                   Bharatiya Nyaya Sanhita.

                                 3. It is case of dowry death. Prosecution case, in brief,

                   is that marriage of the daughter of informant was solemnized

                   with co-accused Rakesh Kumar in the year 2025 and thereafter,

                   all the F.I.R. named accused persons, including this petitioner,

                   killed her due to non-fulfillment of demand of dowry.

                                 4. Learned counsel for the petitioner submits that

                   petitioner is innocent and has committed no offence. Petitioner

                   is father-in-law of the deceased and he is simply victim of over-

                   implication. Allegation against petitioner is general and
            Patna High Court CR. MISC. No.78337 of 2025(3) dt.31-03-2026
                                                        2/2




                      omnibus. Petitioner is separate in mess and property and has got

                      no concern with family affairs of the deceased. He further

                      submits that thrust of accusation is against husband of the

                      deceased who is already in custody. As a matter of fact,

                      deceased herself committed suicide and doctor has also opined

                      the cause of death as Asphyxia as a result of antemortem

                      hanging. Petitioner claims clean antecedent.

                                   5. Learned counsel for the informant vehemently

                      opposed the bail application.

                                   6. Considering the nature of accusation and the fact

                      that husband of the deceased in already in custody, this

                      anticipatory bail is allowed and it is ordered that let the above

                      named petitioner in the event of his arrest/surrender before the

                      court below within a period of eight weeks from today, be

                      enlarged on bail on furnishing bail-bond of Rs. 10,000/- (ten

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

                      satisfaction of learned Sessions Judge, Aurangabad             in

                      connection with Pauthu P. S. Case No. 63 of 2025, subject to

                      condition as laid down under Section 482 (2) BNSS.



                                            (Prabhat Kumar Singh, J)
Navya/-
U       T

Continue reading with your account

Checking your session…