Patna High Court

Urmila DeviversusThe State of Bihar

Decided: 12 March 2026
Disposal: BAIL GRANTED
Bench: SATYAVRAT VERMA

Holding

The Court granted anticipatory bail to the petitioner subject to bond and surety conditions under Section 482(2) of the BNSS.

Summary

The petitioner, Urmila Devi, sought anticipatory bail fearing arrest in a 2016 case registered under Sections 341, 323, 324, 307, 379, 504 and 34 of the IPC. She contended she has a clean antecedent, is a woman, and was falsely implicated by the informant, who alleged an assault on 21‑01‑2016 and the theft of a mangalsutra and Rs.1,200. The petitioner argued that the investigation had dragged on for ten years without any arrest or application of Sections 82 and 83 CrPC. The State opposed the bail. The Court, considering the petitioner’s gender, clean record and the prolonged inactivity of the investigation, granted anticipatory bail subject to a Rs.10,000 bond, two sureties of equal amount, and compliance with conditions under Section 482(2) of the BNSS.

Issues considered

Whether anticipatory bail should be granted to the petitioner under the circumstances of alleged false implication and prolonged investigation.
Whether the petitioner’s gender and clean antecedent warrant relief despite the serious IPC offences alleged.

Legislation cited

Code of Criminal Procedure, 1973 — s. 482, 82, 83
Indian Penal Code — s. 307, 323, 324, 34, 341, 379, 504

Subjects

anticipatory bail
false implication
women rights
IPC offences
bail conditions
investigation delay

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.86977 of 2025
                   Arising Out of PS. Case No.-56 Year-2016 Thana- SUGAULI District- East Champaran
                 ======================================================
                 Urmila Devi S/o Pundev Mahto Resident of Village- Sripur Gopalpur, P.S.-
                 Sugauli, District- East Champaran

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :       Mr.Dhannjay Kumar No 2
                 For the Opposite Party/s :       Mr.Sanjay Kumar Sharma
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE SATYAVRAT VERMA
                                       ORAL ORDER

2   12-03-2026               1.    Heard learned counsel for the petitioner and

                   learned A.P.P. for the State.

                             2.    The petitioner apprehends her arrest in a case

                   registered for the offences punishable under Sections 341, 323,

                   324, 307, 379, 504 and 34 of IPC.

                             3.    Learned counsel for the petitioner submits that

                   petitioner is a person with clean antecedent and is a woman and

                   the informant alleges that accused persons intercepted him and

                   started assaulting on 21-1-2016 at 10:00 am by iron rod, lathi

                   etc., when he was going to fetch water, further Pundev assaulted

                   him by axe causing injury on head and petitioner snatched

                   mangalsutra of his sister and snatched Rs. 1,200/- from his

                   pocket.

                             4.    Learned counsel for the petitioner submits that
Patna High Court CR. MISC. No.86977 of 2025(2) dt.12-03-2026
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          petitioner has 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

          allegation of snatching mangalsutra and Rs. 1,200/- is

          ornamental. It is also submitted that allegation of assaulting the

          informant is against Pundev. It is further submitted that no doubt

          the case is of the year 2016, but then investigation in the case is

          still continuing, as would manifest from the order impugned. It

          is also submitted that police, in these 10 years, did not make any

          endeavour to arrest the petitioner nor sought process under

          Sections 82 and 83 Cr.PC.

                   5.     Learned A.P.P. for the State opposes the prayer for

          anticipatory bail of the petitioner.

                   6.     Considering the submissions made by the learned

          counsel for the petitioner and taking into consideration the fact

          that petitioner is a woman, the petitioner above-named, in the

          event of her arrest or surrender within a period of six weeks

          from today, be released on anticipatory bail on furnishing bail

          bonds of Rs. 10,000/- (Rupees Ten Thousand) 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 Sugauli P.S. Case No. 56 of 2016, subject to the conditions
              Patna High Court CR. MISC. No.86977 of 2025(2) dt.12-03-2026
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                        as laid down under Section 482 (2) of the BNSS.



                                                  (Satyavrat Verma, J)
Sumit/-

U         T

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