Created by Fuzzy Cloud

Patna High Court

Urmila DeviversusThe State of Bihar

Decided
Disposal
BAIL GRANTED

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

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
                 ======================================================
                 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
Patna High Court CR. MISC. No.8242 of 2026(2) dt.17-02-2026
                                            2/4




          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
Patna High Court CR. MISC. No.8242 of 2026(2) dt.17-02-2026
                                            3/4




          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
           Patna High Court CR. MISC. No.8242 of 2026(2) dt.17-02-2026
                                                       4/4




                                  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


Continue reading with your account

Sign in to read the full judgment. It’s free.

Sign in to read

Checking your session…

For a signed copy suitable for filing, refer to the court's website.