Patna High Court

Govardhan ChauhanversusThe State of Bihar

Decided: 11 February 2026
Disposal: BAIL GRANTED
Bench: KHATIM REZA

Holding

The court granted bail to the petitioner upon furnishing a bond of Rs.10,000 with two sureties of equal amount.

Summary

The petitioner, Govardhan Chauhan, was charged under Sections 304(b), 201 and 34 of the Indian Penal Code for allegedly strangling his daughter‑in‑law over a dowry demand. He contended that he was falsely implicated, asserting that the deceased had committed suicide by ingesting poison and that he had no familial ties to the victims. The petitioner had been in custody since 20 September 2025 and had no prior criminal record, while other co‑accused had already been granted bail. The State opposed the bail application. After considering the evidence and the submissions, the court ordered the petitioner’s release on bail upon furnishing a bond of Rs.10,000 with two sureties of the same amount, subject to the satisfaction of the Chief Judicial Magistrate.

Issues considered

Whether the petitioner is entitled to bail in a case involving alleged dowry death under Sections 304(b), 201 and 34 IPC.
Whether the circumstances of the death (suicide vs homicide) affect the grant of bail.

Legislation cited

Indian Penal Code — s. 201, 304(b), 34

Subjects

bail
dowry death
IPC
Section 304(b)
Section 201
Section 34
suicide
criminal procedure

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.87059 of 2025
                       Arising Out of PS. Case No.-61 Year-2013 Thana- MANPUR District- Nalanda
                 ======================================================
                 Govardhan Chauhan, S/O Dukhi Chauhan, Resident of Village- Hargawan
                 Bishunpur, PS- Manpur, District- Nalanda
                                                                    ... ... Petitioner/s

                                                       Versus

                 The State of Bihar
                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :       Mr. Binit Kumar, Advocate
                 For the Opposite Party/s :       Mr. Humayou Ahmad Khan, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE KHATIM REZA
                                       ORAL ORDER

3   11-02-2026                  Heard learned counsel for the petitioner and learned

                   A.P.P. for the State.

                                2. The petitioner seeks bail in connection with

                   Manpur P.S. Case No. 61 of 2013 dated 22.09.2013 instituted

                   for the offence punishable under Sections 304(b), 201/34 of the

                   Indian Penal Code.

                                3. As per the F.I.R., the second marriage of the

                   informant’s daughter was solemnized with co-accused Surendra

                   Chauhan. It is alleged that the accused persons including the

                   petitioner strangulated her to death due to non-fulfilment of the

                   demand of the dowry of Rs. 50,000/-.

                                4. Learned counsel for the petitioner submits that the

                   petitioner is innocent and he has been falsely implicated in this

                   case. It is further submitted that the deceased was the second
Patna High Court CR. MISC. No.87059 of 2025(3) dt.11-02-2026
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          wife of Surendra Chauhan.               The petitioner is co-villager of

          husband of the deceased. Neither he has any connection with the

          family of the deceased and her husband nor he is their relative.

          It is further submitted that during the course of investigation, the

          police collected the evidence which demonstrates that the

          deceased       committed        suicide     by       swallowing   poisonous

          substance. It is further submitted that father-in-law of the

          deceased and the first wife of Surendra Chauhan (Sautan of the

          deceased) have been granted bail vide order dated 22.01.2026

          passed by co-ordinate Bench of this Court in Criminal

          Miscellaneous No. 1648 of 2026. The husband of the deceased

          has been granted bail by lower court itself. Lastly, it has been

          submitted that the petitioner is in custody since 20.09.2025

          having no criminal antecedents. Charge-sheet has been

          submitted in the case.

                       5. Learned A.P.P. has opposed the prayer for bail of

          the petitioner.

                       6. Having considered the facts and circumstances of

          the case and submissions of learned counsel for the parties, let

          the petitioner be released on bail upon furnishing bail bonds of

          Rs. 10,000/- (ten thousand) with two sureties of the like amount

          each to the satisfaction of the learned Chief Judicial Magistrate,
           Patna High Court CR. MISC. No.87059 of 2025(3) dt.11-02-2026
                                                       3/3




                     Nalanda at Biharsharif in connection with Manpur P.S. Case No.

                     61 of 2013.


                                                                      (Khatim Reza, J)

premchand/-

U      T

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