Patna High Court

Laldeo MahtoversusThe State of Bihar

Decided: 11 February 2026
Disposal: BAIL REJECTED
Bench: R P MISHRA

Holding

The court held that bail could not be granted as the nature and gravity of the dowry‑death accusation, coupled with specific allegations, warranted the petitioner’s continued custody.

Summary

The petitioner, Laldeo Mahto, sought bail in a dowry‑death case (Dariyapur P.S. Case No. 449 of 2025) under Sections 80 and 3(5) of the Bharatiya Nyaya Sanhita, 2023. The prosecution alleged that the deceased was killed by her husband and in‑laws for non‑payment of dowry, and the petitioner, the husband, was implicated. The petitioner contended he was innocent, had no dowry demand, and the allegations were vague and omnibus, also noting his lack of prior criminal record. The State argued that specific allegations were made and witnesses supported the prosecution, opposing bail. The High Court, after considering the seriousness of the offence and the nature of the accusations, refused bail, directing the trial court to expedite the trial and allowing a future bail application if the trial exceeds four months.

Issues considered

Whether bail should be granted to the accused under Sections 80 and 3(5) of the Bharatiya Nyaya Sanhita, 2023 in a dowry‑death case.
Whether the allegations against the petitioner are sufficiently specific to justify denial of bail.
Whether the gravity of the offence warrants continued custody pending trial.

Legislation cited

Bharatiya Nyaya Sanhita, 2023 — s. 3(5), 80

Subjects

bail
dowry death
Section 80
Section 3(5)
Bharatiya Nyaya Sanhita
criminal procedure
specific allegations
trial expedite

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.80356 of 2025
                      Arising Out of PS. Case No.-449 Year-2025 Thana- DARIYAPUR District- Saran
                 ======================================================
                 Laldeo Mahto Son of Krishna Mahto Resident Of Village -Tarwan Mangarpal,
                 Ps -Dariyapur, Dist- Saran

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :       Mr. Prabhat Kumar Singh, Advocate
                 For the Opposite Party/s :       Mr. Amitesh Kumar, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE RUDRA PRAKASH
                 MISHRA
                                       ORAL ORDER

3   11-02-2026                          Heard learned counsel for the petitioner, learned

                   APP for the State and perused the case diary.

                                2. The petitioner seeks bail in connection with

                   Dariyapur P.S. Case No. 449 of 2025, instituted for the offences

                   punishable under Sections 80 and 3(5) of the Bharatiya Nyaya

                   Sanhita, 2023.

                                3. The prosecution case, in short, is that daughter of

                   the informant has been done to death by her husband and in-

                   laws 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. Charge-sheet has been submitted in this case.

                   Learned counsel for the petitioner also submitted that the
Patna High Court CR. MISC. No.80356 of 2025(3) dt.11-02-2026
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          petitioner is husband of the deceased and their marriage was

          solemnized nine years ago. It is next submitted that the

          petitioner has never made any demand of dowry from the

          deceased. The allegation levelled against the petitioner is not

          specific rather the same is general and omnibus in nature. It is

          further submitted that the petitioner as being husband of the

          deceased has been falsely implicated in this case. The petitioner

          is in custody since 14.07.2025 and has got no criminal

          antecedent.

                       5. Learned APP for the State has vehemently opposed

          the prayer for grant of bail to the petitioner and submitted that

          there is specific allegation levelled against the petitioner. It is

          further submitted that in paragraph nos. 3 and 4 of the case

          diary, it transpires that the witnesses have supported the

          prosecution case. Hence, the petitioner does not deserve the

          privilege of bail.

                       6. Considering the aforesaid facts and circumstances

          of the case, nature of accusation and the gravity of the offence,

          this Court is not inclined to grant bail to the petitioner.

                       7. The prayer is rejected. The trial Court is directed to

          expedite the Trial. However, if the trial is not concluded within a

          period of four months from the date of receipt/production, the
             Patna High Court CR. MISC. No.80356 of 2025(3) dt.11-02-2026
                                                         3/3




                       petitioner will have liberty to renew his prayer for bail in the

                       Court below.



                                                                   (Rudra Prakash Mishra, J)
Rajorshi/-

U       T

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