Patna High Court
Rukmani Devi @ Rookmani Devi @ Rukmini DeviversusThe State of Bihar
- Decided
- Disposal
- BAIL GRANTED
- Bench
- SATYAVRAT VERMA
Holding
The Court granted anticipatory bail to the petitioners subject to conditions, finding no sufficient ground to deny bail.
Summary
The petitioners, who are the mother, father, sister and brother of the accused Chandan, applied for anticipatory bail fearing arrest in a case registered under Section 376 of the IPC and Sections 3 and 4 of the Dowry Prohibition Act, 1961. They alleged that the complainant had a consensual relationship with Chandan, that dowry demands were made later, and that the entire family was falsely implicated. The State opposed the bail, arguing the seriousness of the offences. The Court examined the clean antecedent of the petitioners and the lack of direct evidence linking them to the alleged crimes. It held that there was no sufficient ground to deny anticipatory bail and ordered their release on bail with strict conditions. The order was made under the inherent powers of the court under Section 482(2) of the Criminal Procedure Code.
Issues considered
- Whether the petitioners are entitled to anticipatory bail in a case involving alleged rape and dowry demands.
- Whether the allegations against the family members constitute sufficient ground to deny bail.
- Whether the family members can be held liable for the alleged dowry demand and related offences.
Legislation cited
- Code of Criminal Procedure, 1973 — s. 482(2)
- Dowry Prohibition Act, 1961 — s. 3, 4
- Indian Penal Code — s. 376
Subjects
- anticipatory bail
- dowry prohibition
- rape
- false implication
- family members
- criminal procedure
Judgment
IN THE HIGH COURT OF JUDICATURE AT PATNA
CRIMINAL MISCELLANEOUS No.86161 of 2025
Arising Out of PS. Case No.-51 Year-2024 Thana- MAHILA P.S. District- Patna
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1. Rukmani Devi @ Rookmani Devi @ Rukmini Devi W/O Satyendra Das
Resident of village- Gopalpur, P.o. Jamuk, P.S. Paras Bigha, District-
Jehanabad, Bihar- 804429
2. Satyendra Das @ Satyendra Kumar Das S/O Shaligram Das Resident of
village- Gopalpur, P.o. Jamuk, P.S. Paras Bigha, District- Jehanabad, Bihar-
804429
3. Shobha Kumari @ Shobha Kumar @ Shobha Kumari Sabanam D/O
Satyendra Das Resident of village- Gopalpur, P.o. Jamuk, P.S. Paras Bigha,
District- Jehanabad, Bihar- 804429
4. Suraj Kumar @ Suraj Kumar Das S/O Satyendra Das Resident of village-
Gopalpur, P.o. Jamuk, P.S. Paras Bigha, District- Jehanabad, Bihar- 804429
... ... Petitioner/s
Versus
The State of Bihar Patna
... ... Opposite Party/s
======================================================
Appearance :
For the Petitioner/s : Mr.Abhishek Kumar
For the Opposite Party/s : Mr.Rana Randhir Singh
======================================================
CORAM: HONOURABLE MR. JUSTICE SATYAVRAT VERMA
ORAL ORDER
2 19-01-2026 1. Heard learned counsel for the petitioners and
learned A.P.P. for the State.
2. The petitioners apprehend their arrest in a case
registered for the offences punishable under Section 376 of the
IPC and Sections 3 and 4 of the Dowry Prohibition Act, 1961.
3. Learned counsel for the petitioners submits that the
petitioners are persons with clean antecedent and the informant
alleges that Chandan on false promise of marriage established
physical relation on 13-11-2022 at his maternal uncle’s house,
Patna High Court CR. MISC. No.86161 of 2025(2) dt.19-01-2026
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thereafter again established relation on 4-5-2022 at her Bhabhi’s
resident, next alleges that relationship continued for two years
and when she insisted for marriage, Chandan started demanding
Rs. 22 lakh and a car on the pretext that if demand is not met he
will post inappropriate videos on social media, accordingly she
petitioned the Mahila PS on 18-7-2023, when accused persons
came and assured that marriage would be performed and 19-2-
2024 was fixed for marriage. It is next alleged that mother of
Chandan demanded Rs. 10 lakh but later accused persons resiled
from marriage.
4. Learned counsel for the petitioners submits that
that petitioners have been falsely implicated in the instant case
by the informant. It is next submitted that from perusal of the
allegations as alleged in the FIR, it would manifest that the
informant alleges that she was in a relationship for the last two
years with Chandan and they established physical relation and
when she insisted for marriage, Chandan started demanding
dowry. It is further submitted that in order to coerce Chandan
into submission, his entire family members have been
implicated in the instant case. It is submitted that petitioners are
mother, father, sister and brother of Chandan in the instant
anticipatory bail application.
Patna High Court CR. MISC. No.86161 of 2025(2) dt.19-01-2026
3/3
5. Learned A.P.P. for the State opposes the prayer for
anticipatory bail of the petitioners.
6. Considering the submissions made by the learned
counsel for the petitioners, the petitioners above-named, in the
event of their arrest or surrender before the learned trial court
within a period of six weeks from today, be released on
anticipatory bail on furnishing bail bonds of Rs. 10,000/-
(Rupees Ten Thousand) each with two sureties of the like
amount each to the satisfaction of the learned trial court where
the case is pending/successor court in connection with Mahila
P.S. Case No. 51 of 2024, subject to the conditions as laid down
under Section 482 (2) of the BNSS.
(Satyavrat Verma, J)
Sumit/-
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