Patna High Court

Ladli Khatoon @ Ladli PraweenversusThe State of Bihar

Decided: 9 April 2026
Disposal: DISMISSED
Bench: PURNENDU SINGH

Holding

The court held that the seriousness of the offences precludes the grant of pre‑arrest bail.

Summary

The petitioners, three women residents of Mansurpur Chamarua, applied for pre‑arrest bail in connection with a case registered under Sections 61(2) and 80 of the BNS and Sections 3 and 4 of the Dowry Prohibition Act. The application was heard before Hon’ble Mr. Justice Purnendu Singh. The court examined whether the seriousness of the alleged offences justified the grant of pre‑arrest bail. Considering the gravity of the charges, the judge was not inclined to enlarge the petitioners on bail. Consequently, the application for pre‑arrest bail was dismissed.

Issues considered

Whether the petitioners are entitled to pre‑arrest bail despite the seriousness of the offences under the BNS and Dowry Prohibition Act

Legislation cited

BNS — s. 61(2), 80
Dowry Prohibition Act — s. 3, 4

Subjects

pre‑arrest bail
seriousness of offence
dowry prohibition
criminal procedure
bail jurisprudence

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.86357 of 2025

                      Arising Out of PS. Case No.-234 Year-2025 Thana- KARJA District- Muzaffarpur
                 ======================================================
           1.     Ladli Khatoon @ Ladli Praween D/O Md. Reyaz @ Md. Raiyaj Resident of
                 village- Mansurpur Chamarua, P.S.-Karja, District-Muzaffarpur
           2.    Mushraf Khatoon @ Mosarat @ Mosarant Khatoon @ Musaraf Khatun W/O
                 Md. Jamal Resident of village- Mansurpur Chamarua, P.S.-Karja, District-
                 Muzaffarpur
           3.    Nargis Khatoon @ Nargis Praween D/O Md. Reyaz @ Md. Raiyaj Resident
                 of village- Mansurpur Chamarua, P.S.-Karja, District-Muzaffarpur

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :        Mr. Sanjay Kumar @ S.K., Advocate
                 For the Opposite Party/s :        Mr. Ajit Kumar, A.P.P.
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE PURNENDU SINGH
                                       ORAL ORDER

3   09-04-2026                     Heard Mr. Sanjay Kumar @ S.K., learned counsel

                   appearing on behalf of the petitioners and Mr. Ajit Kumar,

                   learned APP for the State.

                                 2. The petitioners seek pre-arrest bail in connection

                   with Karja P.S. Case No. 234 of 2025 registered for the offence

                   punishable under Sections 61(2), 80 of the BNS and Sections

                   3/4 of the Dowry Prohibition Act.

                                 3. Considering the seriousness of offence, I am not

                   inclined to enlarge the petitioners on pre-arrest bail.
              Patna High Court CR. MISC. No.86357 of 2025(3) dt.09-04-2026
                                                          2/2




                                     4. Accordingly, the present application stands

                        dismissed.



                                                  (Purnendu Singh, J)
Niraj/-

U         T

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