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Patna High Court

Ranjan MahtoversusThe State of Bihar

Decided
Disposal
DISMISSED

Holding

The Court refused to grant bail to the petitioner at this stage.

Summary

The petitioner, Ranjan Mahto, was charged under Sections 328, 201, 34 and 304B of the Indian Penal Code for allegedly administering rat poison to his wife, Sabnam Devi, leading to her death. He has been in judicial custody since 15 April 2024, and the prosecution relies on a post‑mortem report indicating asphyxia due to ante‑mortem injuries, though the exact injuries were not specified. The petitioner’s counsel argued that he is innocent, that two co‑accused are absconding, no witnesses have been examined, and that he has no prior criminal record. The State opposed bail, emphasizing the seriousness of the offence and the incomplete forensic findings. After hearing both sides, the Court declined to grant bail, directing that the petitioner may re‑apply after six months and ordering the trial court to conclude the trial within six months.

Issues considered

  • Whether bail should be granted to an accused in a murder‑dowry case under Sections 328, 201, 34 and 304B IPC.
  • Whether the evidence on record, including the post‑mortem report, justifies denial of bail.
  • Whether the petitioner poses a risk of fleeing or tampering with evidence.

Legislation cited

Subjects

  • bail
  • murder
  • dowry death
  • IPC
  • Criminal Procedure Code
  • judicial custody
  • trial delay

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.85680 of 2025
                     Arising Out of PS. Case No.-122 Year-2024 Thana- ATHMALGOLA District- Patna
                 ======================================================
                 Ranjan Mahto Son of Binod Mahto Resident of village- Ram Nagar diyara
                 Bind Toil, Ps- Athmalgola, Dist- Patna

                                                                                 ... ... Petitioner/s
                                                      Versus
                 The State of Bihar

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :      Mr. Niranjan Prasad Singh
                 For the Opposite Party/s :      Mr. Arun Kumar
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE ASHOK KUMAR PANDEY
                                       ORAL ORDER

4   17-03-2026                  Heard learned counsel for the petitioner and the

                   learned APP for the State.

                                2. The petitioner has prayed for bail in connection

                   with Session Trial No. 1376 of 2024 arising out of Athmalgola

                   P.S. Case No. 122 of 2024 registered for the offence punishable

                   under Sections 328, 201, 34, 304(B) of the Indian Penal Code.

                                3. The case of the prosecution, in short, is that the

                   petitioner was married to the deceased, namely, Sabnam Devi,

                   three years ago. They also had a daughter out of wedlock with

                   the petitioner. It is further alleged that the deceased was

                   subjected to cruelty on account of non-fulfillment of dowry

                   demand. It is also alleged that the petitioner, along with others,

                   forcefully administered rat killer to the deceased. On

                   09.04.2024, when the informant reached the matrimonial house
Patna High Court CR. MISC. No.85680 of 2025(4) dt.17-03-2026
                                            2/3




          of the deceased, the in-laws and the deceased were not there.

          The informant believes that the deceased had been killed by

          administering poison.

                       4. Learned counsel appearing on behalf of the

          petitioner has submitted that petitioner is innocent and has

          committed no offence. He has been falsely implicated in this

          case. He also submits that the stage of trial was called from the

          learned trial court. From perusal of the report of the learned trial

          court, it is clear that two accused persons, namely, Laldhari

          Mahto and Police Mahto were absconding and the trial of this

          petitioner has been separated. He also submits that the petitioner

          is languishing in judicial custody since 15.04.2024 and till today

          no witness has been examined. He further submits that a

          statement has been made in para 3 of the petition that petitioner

          has no criminal antecedent.

                       5. The application for bail is opposed by learned APP

          for the State and submits that from perusal of the post mortem

          report, it transpires that the same was conducted on 15.04.2024,

          i.e., after six days of the death of the deceased. Although the

          doctor has opined that the cause of death is Asphyxia due to

          ante-mortem injuries, it has not been specified what ante-

          mortem injury was found on the person of the deceased.
           Patna High Court CR. MISC. No.85680 of 2025(4) dt.17-03-2026
                                                       3/3




                     Furthermore, the viscera was not preserved as all viscera was

                     decomposed.

                                  6. In any view of the matter, the death has taken place

                     in the matrimonial house. The petitioner is the husband and it is

                     onus upon him to disclose the circumstances under which the

                     deceased died. However, the learned counsel for petitioner has

                     not been able to disclose the same.

                                  7. Having heard learned counsel for the parties and

                     considering the facts and circumstances of the case, this Court is

                     not inclined to enlarge the petitioner on bail at this stage,

                     however, the petitioner will be at liberty to renew his prayer for

                     bail after six months if the trial is not concluded.

                                  8. Learned trial court is directed to conclude the trial

                     within a period of six months and to conduct a calendar trial of

                     this petitioner, so that it may be concluded within six months.



                                                    (Ashok Kumar Pandey, J)
Sudhanshu/-

U      T


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