Patna High Court

Lalman ManjhiversusThe State of Bihar

Decided: 8 January 2026
Disposal: ALLOWED
Bench: SUNIL DUTTA MISHRA

Holding

Anticipatory bail was granted subject to the conditions prescribed under Section 482(2) of the BNSS.

Summary

The petitioners, members of the Manjhi family, sought anticipatory bail fearing arrest in a dowry death case (PS Case No. 290 of 2025) filed under Sections 80(2) & 3(5) of the Bihar Negotiable Substances Act and Sections 3 and 4 of the Dowry Prohibition Act. The prosecution alleged that the petitioners participated in the dowry death of the informant's daughter, while the petitioners contended they were innocent, had no involvement, and that the deceased had locked herself in a room and committed suicide. Their counsel emphasized the lack of specific evidence, the petitioners' clean record, and their willingness to cooperate with the investigation. The State opposed the anticipatory bail. After considering the submissions, the Court ordered that, should the petitioners be arrested or surrender within six weeks, they be released on bail upon furnishing a bail bond of Rs.10,000 with two sureties each, subject to the conditions of Section 482(2) of the BNSS.

Issues considered

Whether anticipatory bail should be granted to the petitioners under Sections 80(2) & 3(5) of the BNS Act and Sections 3/4 of the Dowry Prohibition Act.
Whether the allegations against the petitioners are specific enough to justify denial of bail.

Legislation cited

Dowry Prohibition Act — s. 3, 4

Subjects

anticipatory bail
dowry death
criminal procedure
Section 482
bail conditions
false implication

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.81214 of 2025
                      Arising Out of PS. Case No.-290 Year-2025 Thana- DARAUNDA District- Siwan
                 ======================================================
           1.     Lalman Manjhi S/o- Bangali Manjhi Resident of Purbi Hansar P.S-
                  Daraunda, Dist- Siwan
           2.    Shanti Devi W/o- Lalman Manjhi Resident of Purbi Hansar P.S- Daraunda,
                 Dist- Siwan
           3.    Munna Manjhi S/o- Lalman Manjhi Resident of Purbi Hansar P.S-
                 Daraunda, Dist- Siwan
           4.    Manoj Manjhi @ Manoj Kumar Manjhi S/o- Lalman Manjhi Resident of
                 Purbi Hansar P.S- Daraunda, Dist- Siwan
           5.    Nisha Devi W/o- Manoj Manjhi @ Manoj Kumar Manjhi Resident of Purbi
                 Hansar P.S- Daraunda, Dist- Siwan
           6.    Anita Devi W/o- Munna Manjhi Resident of Purbi Hansar P.S- Daraunda,
                 Dist- Siwan

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :      Mr. Anil Chandra, Advocate
                 For the Opposite Party/s :      Mr. Madhura Nand Jha, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE SUNIL DUTTA MISHRA
                                       ORAL ORDER

2   08-01-2026                    Heard learned counsel for the petitioners and learned

                   A.P.P. for the State.

                                2. The petitioners apprehend their arrest in connection

                   with Daraunda P.S. Case No. 290 of 2025 instituted under

                   Sections 80(2) & 3(5) of the BNS and Section 3/4 of the D.P.

                   Act.

                                3. As per the prosecution case, the accused persons

                   including the petitioners committed dowry death of the daughter
Patna High Court CR. MISC. No.81214 of 2025(2) dt.08-01-2026
                                            2/3




          of the informant.

                       4. Learned counsel for the petitioners submits that

          petitioners are innocent and have been falsely implicated in this

          case. He further submits that the petitioners are in laws of the

          deceased and they have no concern with the affairs of the

          deceased and her husband. He submits that the deceased locked

          herself in a room from inside and committed suicide and the

          petitioners have been implicated only on suspicion. He further

          submits that the allegation against the petitioners are general and

          omnibus and the husband of the deceased, namely, Pritam

          Manjhi is in judicial custody since 11.06.2025. He further

          submits that the petitioners have no criminal antecedent and

          they undertake to cooperate in the trial and investigation and

          also undertake not to temper with the evidence.

                       5. Learned A.P.P. for the State opposes the prayer for

          anticipatory bail.

                       6. Considering the facts and circumstances of the case

          and submissions of learned counsel for the parties, in the event

          of arrest or surrender before the Court below within six weeks

          from today, the petitioners be released on bail upon furnishing

          bail bonds of Rs.10,000/- (Rupees Ten Thousand) each with two

          sureties of the like amount to each to the satisfaction of the
           Patna High Court CR. MISC. No.81214 of 2025(2) dt.08-01-2026
                                                       3/3




                     learned S.D.J.M., Siwan in connection with Daraunda P.S. Case

                     No. 290 of 2025, subject to the conditions laid down in Section

                     482(2) of the BNSS.



                                             (Sunil Dutta Mishra, J)
AjayMishra/-

U      T

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