Patna High Court
Ravi Sawarn @ Ravi SavarnversusThe State of Bihar
- Decided
- Disposal
- BAIL REJECTED
- Bench
- PRABHAT KUMAR SINGH
Holding
Anticipatory bail was denied as the court found the allegations serious and the risk of interference with the investigation substantial.
Summary
The petitioner, Ravi Sawarn, sought anticipatory bail fearing arrest in a criminal case registered under Sections 103(1), 80 and 3(5) of the Bharatiya Nyaya Sanhita. The prosecution alleges that the petitioner, as husband of the deceased, was involved in the dowry‑related killing of the informant's daughter, with a post‑mortem indicating an unnatural death. The petitioner argued that the allegations were unfounded and that anticipatory bail was warranted to protect his liberty. The court examined the seriousness of the dowry death charge, the evidentiary material including the post‑mortem report, and the statutory provisions governing anticipatory bail. Considering the gravity of the offence and the risk of tampering with evidence, the court refused the anticipatory bail application. Consequently, the petition for anticipatory bail was dismissed.
Issues considered
- Whether anticipatory bail should be granted to the petitioner under Sections 103(1), 80 and 3(5) of the Bharatiya Nyaya Sanhita in a dowry‑death case
Legislation cited
- Bharatiya Nyaya Sanhita — s. 103(1), 3(5), 80
Subjects
- anticipatory bail
- dowry death
- Bharatiya Nyaya Sanhita
- Section 103
- Section 80
- Section 3(5)
- criminal procedure
Judgment
IN THE HIGH COURT OF JUDICATURE AT PATNA
CRIMINAL MISCELLANEOUS No.85187 of 2025
Arising Out of PS. Case No.-259 Year-2025 Thana- KAJI MUHAMMADPUR District-
Muzaffarpur
======================================================
Ravi Sawarn @ Ravi Savarn S/O Girish Prasad Singh Resident of Village-
Gangeya @ Parmanandpur, P.S- Katra, District- Muzaffarpur.
... ... Petitioner/s
Versus
The State of Bihar Bihar
... ... Opposite Party/s
======================================================
Appearance :
For the Petitioner/s : Mr. Upendra Kumar Chaubey, Advocate
For the Opposite Party/s : Mr. Shailendra Kumar Singh, APP
======================================================
CORAM: HONOURABLE MR. JUSTICE PRABHAT KUMAR SINGH
ORAL ORDER
3 15-01-2026 Heard learned counsel for the petitioner and learned
APP for the State.
2. Petitioner apprehend arrest in a case registered for
the offences punishable under Sections 103(1), 80, 3(5) of the
Bharatiya Nyaya Sanhita.
3. As per prosecution case, petitioner is the husband
of the deceased. It is alleged that all the FIR named accused
persons have killed the daughter of the informant for dowry.
Post-mortem report reveals that the death of deceased was
unnatural and under suspicious circumstances.
4. Considering the nature of accusation and gravity of
the offence, prayer for anticipatory bail of the petitioners is
Patna High Court CR. MISC. No.85187 of 2025(3) dt.15-01-2026
2/2
refused.
(Prabhat Kumar Singh, J)
khushbu/-
U T
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