Patna High Court
Urmila DeviversusThe State of Bihar
- Decided
- Disposal
- BAIL GRANTED
- Bench
- ARUN KUMAR JHA
Holding
The court granted bail to the petitioner, finding the allegations vague and the circumstances warranting release on bond.
Summary
Urmila Devi, the mother‑in‑law of a deceased woman, was charged under Section 80(2) read with Section 3(5) of the B.N.S., 2023 and Sections 3 and 4 of the Dowry Prohibition Act for allegedly killing the daughter of an informant over a dowry dispute. The petitioner contended that the allegation was false, asserting that the deceased had committed suicide by hanging and that no dowry demand had been made. The prosecution argued that the petitioner, along with co‑accused, had tortured the victim and caused her death. The court noted the vague and non‑specific nature of the allegations against the petitioner, her clean antecedents, the grant of bail to a similarly situated co‑accused, and the fact that a charge‑sheet had only been submitted. Consequently, the court ordered the release of the petitioner on bail with a bond of Rs.10,000 and two sureties, subject to conditions under Section 480(3) of the B.N.S. and other stipulated terms.
Issues considered
- Whether the allegations against the petitioner under the B.N.S., 2023 and the Dowry Prohibition Act are sufficiently specific to deny bail.
- Whether the petitioner is entitled to bail considering the nature of the offence, her antecedents, and the circumstances of custody.
Legislation cited
- B.N.S., 2023 — s. 3(5), 480(3), 80(2)
- Dowry Prohibition Act — s. 3, 4
Subjects
- bail
- dowry death
- Section 80(2) B.N.S.
- Section 3(5) B.N.S.
- Section 3 Dowry Act
- Section 4 Dowry Act
- suicide
- mother‑in‑law
- criminal procedure
Judgment
IN THE HIGH COURT OF JUDICATURE AT PATNA
CRIMINAL MISCELLANEOUS No.8242 of 2026
Arising Out of PS. Case No.-148 Year-2025 Thana- SANJHOLI District- Rohtas
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Urmila Devi Wife of Jaymangal Singh Resident of Village- Bensagar
(Khutahan), P.S.- Sanjhauli, District- Rohtas
... ... Petitioner/s
Versus
The State of Bihar
... ... Opposite Party/s
======================================================
Appearance :
For the Petitioner/s : Mr. Nagendra Upadhyay, Advocate
For the Opposite Party/s : Mr. Braj Kishore Pd., APP
For the Informant : Mr. Satyendra Pandey, Advocate
======================================================
CORAM: HONOURABLE MR. JUSTICE ARUN KUMAR JHA
ORAL ORDER
2 17-02-2026 Heard learned counsel for the petitioner, learned
counsel for the informant and learned A.P.P. for the State.
2. In the present case, the petitioner seeks bail in
connection with Sanjhauli P.S. Case No. 148 of 2025 dated
31.07.2025, registered for the offences punishable under Section
80(2) read with Section 3(5) of the B.N.S., 2023 and Sections 3
and 4 of the D.P. Act.
3. As per the prosecution case, on account of non-
fulfillment of dowry demand, the daughter of the informant was
done to death by the petitioner and other co-accused persons.
The petitioner is mother-in-law of the deceased.
4. Learned counsel appearing on behalf of the
petitioner submits that petitioner is innocent and he has falsely
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been implicated in the present case. The petitioner lives
separately from the deceased and her husband, and has no
concern with the affairs of the deceased or her husband. The
allegation levelled against the petitioner is false and concocted.
The true fact of the case is that some altercation took place
between the deceased and her husband and the deceased
committed suicide by hanging herself. Prior to lodging of the
FIR, no complaint was made regarding any dowry demand or
torturing the deceased. The post-mortem report shows that the
death was caused due to asphyxia due to hanging and it shows
the deceased committed suicide. Even though no cogent
material has come up against the petitioner, the police submitted
charge-sheet against him. Learned counsel next submits that
petitioner is having clean antecedent. Learned counsel further
submits that co-accused, Bikash Kumar Yadav, has been granted
bail by this Court vide order dated 28.01.2026 passed in
Criminal Misc. No. 4232 of 2026. Learned counsel lastly
submits that the petitioner is in custody since 18.08.2025.
5. Learned A.P.P. appearing on behalf of the State
as well as the learned counsel for the informant oppose the
submissions made on behalf of the petitioner. Learned counsel
for the informant submits that there is specific allegation against
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the petitioner and other co-accused persons who used to torture
the daughter of the informant and further used to stop her meals
and ultimately they killed her on account of non-fulfillment of
their demand of dowry.
6. Having regard to the facts and circumstances and
submissions made on behalf of the parties and considering the
fact that the petitioner is said to be the mother-in-law of the
deceased and further considering the vague and non-specific
nature of allegation against the petitioner and also considering
the grant of bail to similarly placed co-accused and period of
custody of the petitioner, her clean antecedent along with
submission of charge-sheet, the petitioner, above-named, is
directed to be released on bail, on furnishing bail bonds of
Rs.10,000/- (Rupees Ten Thousand Only) with two sureties of
the like amount each to the satisfaction of learned Additional
Chief Judicial Magistrate-I, Bikramganj, Rohtas / concerned
Court, in connection with Sanjhauli P.S. Case No. 148 of 2025,
subject to the condition laid down under Section 480(3) of the
B.N.S.S. and other following conditions:
(i) One of the bailors will be a close relative of the
petitioner.
(ii) The petitioner will remain present on each and
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every date fixed by the court below, if so required
by the learned trial Court.
(iii) In case of absence on three consecutive dates
or in violation of the terms of the bail, the bail
bond of the petitioner will be liable to be cancelled
by the Court concerned.
(Arun Kumar Jha, J)
Ashish/-
U
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