Patna High Court
Manoranjan SinghversusThe State of Bihar
- Decided
- Disposal
- BAIL GRANTED
- Bench
- SANDEEP KUMAR
Holding
The High Court granted anticipatory bail to the petitioner, subject to bail bond and maintenance conditions.
Summary
The petitioner, Manoranjan Singh, sought anticipatory bail fearing arrest in a dowry‑related assault case (Mahila PS Case No. 14 of 2025) involving offences under Sections 126(2), 115(2), 85, 351(2), 352, 3(5) of the B.N.S. and Section 3 of the Dowry Prohibition Act. The State opposed the bail, alleging the petitioner assaulted the victim to demand dowry. Relying on the Supreme Court’s guidelines in Arnesh Kumar v. State of Bihar, the Court examined whether the arrest was necessary and whether anticipatory bail could be granted. The Court allowed the anticipatory bail, directing the petitioner to furnish a bail bond of Rs. 10,000 with two sureties and to comply with conditions under Section 438(2) CrPC and Section 482 of the High Court’s powers. Additionally, the Court ordered the petitioner to pay a monthly maintenance of Rs. 6,000 to the informant, subject to any further maintenance proceedings.
Issues considered
- Whether anticipatory bail should be granted under Section 438 CrPC in view of the alleged dowry‑related offences.
- Whether the principles laid down in Arnesh Kumar v. State of Bihar regarding unnecessary arrests apply.
- Whether the Court can impose a maintenance obligation as a condition of bail.
Legislation cited
- B.N.S. — s. 115, 126, 3, 351, 352, 85
- Code of Criminal Procedure, 1973 — s. 438, 482
- Dowry Prohibition Act — s. 3
Subjects
- anticipatory bail
- dowry prohibition
- Section 438 CrPC
- Arnesh Kumar principle
- maintenance order
- Bihar criminal law
Judgment
IN THE HIGH COURT OF JUDICATURE AT PATNA
CRIMINAL MISCELLANEOUS No.82892 of 2025
Arising Out of PS. Case No.-14 Year-2025 Thana- MAHILA PS District- Gopalganj
======================================================
Manoranjan Singh Son of Late Shivnath Singh R/o Bhawalpur, P.S.-
Madhaura, District- Saran
... ... Petitioner/s
Versus
The State of Bihar
... ... Opposite Party/s
======================================================
Appearance :
For the Petitioner/s : Mr.Madhukar Anand, Advocate
For the Opposite Party/s : Mr.Md. Anzarul Haque Sahara, APP
======================================================
CORAM: HONOURABLE MR. JUSTICE SANDEEP KUMAR
ORAL ORDER
3 23-02-2026 Heard learned counsel for the petitioner and learned
APP for the State.
2. The petitioner apprehends his arrest in
connection with Mahila (Gopalganj) P.S. Case No. 14 of 2025
for the offences under Sections 126(2), 115(2), 85, 351(2), 352,
3(5) of B.N.S. and under Section ¾ of the Dowry Prohibition
Act.
3. As per the prosecution case, the petitioner is
accused of assaulting and torturing the victim for demand of
dowry.
4. It has been submitted by the learned counsel for the
petitioner that the petitioner is innocent and he has falsely been
implicated in this case.
5. Learned counsel for the State has opposed the
Patna High Court CR. MISC. No.82892 of 2025(3) dt.23-02-2026
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application of the petitioner.
6 . Considering the submission of the parties and in
view of the law laid down by the Hon’ble Supreme Court in the
case of Arnesh Kumar Vs. State of Bihar reported in (2014)
8 SCC 273 , this application of grant of anticipatory
bail is allowed.
7. Let the petitioner, above named, in the event of his
arrest or surrender before the concerned Court below within six
weeks from today, be released on bail on furnishing bail bond of
Rs. 10,000/- (Ten Thousand) with two sureties of the like
amount each to the satisfaction of the learned Sub. Divisional
Judicial Magistrate, Gopalganj /concerned Court below in
connection with Mahila (Gopalganj) P.S. Case No. 14 of 2025,
subject to the conditions laid down in Section 438(2) of the
Code of Criminal Procedure, 1973 / Section 482 of the BNSS.
8. As a condition of this order, the petitioner is
directed to pay a maintenance amount of Rs. 6,000/- from the
month of February, 2026 to the informant and the maintenance
for the month of February, 2026 shall be paid to the informant
before 28.02.2026 and thereafter the maintenance amount from
the month of March, 2026 shall be paid to the informant every
month before the 10th day of the month.
Patna High Court CR. MISC. No.82892 of 2025(3) dt.23-02-2026
3/3
9. It is made clear that the aforesaid maintenance
order will be subject to the outcome of any order of concerned
Court below passed in maintenance proceedings, if any.
(Sandeep Kumar, J)
tusharika/-
U T
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