Patna High Court
Sujit Kumar Madhu @ Sujit Kumar @ MadhuversusThe State of Bihar
- Decided
- Disposal
- BAIL REJECTED
- Bench
- PRABHAT KUMAR SINGH
Holding
Anticipatory bail was denied because the petitioner, as the husband of the deceased, is alleged to have participated in a dowry‑related homicide.
Summary
The petitioner, Sujit Kumar Madhu, was arrested in a dowry death case (PS case No. 345 of 2025) under Sections 80(2) and 3(5) of the Bharatiya Nyaya Sanhita. The prosecution alleges that he, along with others, killed his wife by poisoning her due to non‑payment of dowry. The petitioner contended that he was falsely implicated, had no dowry demands, and that the deceased had committed suicide because of mental illness. The State opposed bail, emphasizing the petitioner’s marital relationship to the deceased and the seriousness of the allegations. The Court, considering the nature of the accusation and the fact that the death occurred within seven years of marriage under unnatural circumstances, refused the petitioner's anticipatory bail.
Issues considered
- Whether anticipatory bail can be granted to a husband accused of dowry death under Sections 80(2) and 3(5) of the Bharatiya Nyaya Sanhita
Legislation cited
- Bharatiya Nyaya Sanhita — s. 3(5), 80(2)
Subjects
- dowry death
- anticipatory bail
- Bharatiya Nyaya Sanhita
- husband-wife homicide
- poisoning
- marital relationship
Judgment
IN THE HIGH COURT OF JUDICATURE AT PATNA
CRIMINAL MISCELLANEOUS No.81754 of 2025
Arising Out of PS. Case No.-345 Year-2025 Thana- LAHERIMUHALLA District- Nalanda
======================================================
Sujit Kumar Madhu @ Sujit Kumar @ Madhu Son of Late Hemant Kumar
Yadav Resident of village - Mathuriya Mahalla, Police Station - Laheri,
District - Nalanda.
... ... Petitioner/s
Versus
The State of Bihar
... ... Opposite Party/s
======================================================
Appearance :
For the Petitioner/s : Mr. Ajay Mukherjee, Advocate
For the Opposite Party/s : Mr. Prem Kumar Jha, A.P.P.
For the Informant : Mr. Arun Kumar Arun, Mr. Aditya Pushkar,
Mr. Anil Kumar, Mr. Karamchand Kumar, Adv
======================================================
CORAM: HONOURABLE MR. JUSTICE PRABHAT KUMAR SINGH
ORAL ORDER
6 13-03-2026 Heard learned counsel for the petitioner, informant
and the State.
2. Petitioner apprehends arrest in Laheri P. S. Case
No. 345 of 2025 registered for the offences punishable under
Sections 80(2), 3(5) of the Bharatiya Nyaya Sanhita.
3. It is a case of dowry death. As per the prosecution
case, marriage of the daughter of informant was solemnized
with this petitioner in the year 2024 and thereafter it is alleged
that this petitioner along with other accused persons killed the
daughter of the informant, due to non-fulfillment of dowry.
4. Learned counsel for the petitioner submits that
petitioner happens to be husband of the deceased and he has
Patna High Court CR. MISC. No.81754 of 2025(6) dt.13-03-2026
2/2
falsely been implicated in this case merely on suspicion.
Petitioner never demanded any dowry nor harassed the
deceased. As a matter of fact, deceased herself committed
suicide by consuming poison as she was mentally ill and a short
tempered lady. Petitioner claims clean antecedent.
5. Learned A.P.P. for the State vehemently opposed
the bail application and submitted that petitioner is husband of
the deceased and there is specific allegation against him that he
along with other accused persons killed the deceased due to
non-fulfillment of demand of dowry, by poisoning her.
6. Considering the nature of accusation and the fact
that petitioner is husband of the deceased, who died within
seven years of marriage in unnatural circumstances, prayer for
anticipatory bail of the petitioner is refused.
(Prabhat Kumar Singh, J)
Navya/-
U T
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