Patna High Court

Shatrudhan Singh @ Satrughan Singh @ D.M.versusThe State of Bihar

Decided: 27 February 2026
Disposal: BAIL GRANTED
Bench: PRABHAT KUMAR SINGH

Holding

The Court held that bail should be granted to the petitioner.

Summary

The petitioner, Shatrudhan Singh, was charged under Section 103(1) of the Bharatiya Nyaya Sanhita for the alleged murder of his daughter‑in‑law. The prosecution’s case is based on the informant’s allegation that the petitioner strangulated the victim, while the post‑mortem report indicated death by asphyxia due to hanging, suggesting suicide. The petitioner’s counsel argued that the informant was not an eyewitness, the only evidence was suspicion, and the deceased’s grandmother turned hostile, asserting no foul play. The State opposed bail, citing the seriousness of the offence. Considering the petitioner’s clean antecedents, the length of custody, the fact that the charge had been framed, and the lack of substantive evidence, the Court granted regular bail on a bond of Rs 10,000 with two sureties.

Issues considered

Whether regular bail can be granted in a murder case under Section 103(1) of the Bharatiya Nyaya Sanhita given the circumstances of the evidence and the petitioner’s antecedents
Whether the post‑mortem finding of death by hanging negates the prosecution’s murder allegation for the purpose of bail

Legislation cited

Bharatiya Nyaya Sanhita — s. 103(1)

Subjects

bail
murder
Section 103
Bharatiya Nyaya Sanhita
suicide
hostile witness
clean antecedent
criminal procedure

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.87134 of 2025
                       Arising Out of PS. Case No.-264 Year-2025 Thana- DHANARUA District- Patna
                 ======================================================
                 Shatrudhan Singh @ Satrughan Singh @ D.M. Son of Mahendra Yadav @
                 Mahendra Singh R/o- Nasirnachak, P.O.- Barni, P.S.- Dhanarua, Dist.- Patna
                 804452, Bihar
                                                                            ... ... Petitioner/s
                                                 Versus
                 The State of Bihar
                                                                     ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :       Mr. Krishna Pd. Singh, Sr. Advocate
                                                  Mr. Vishal Vikram Rana, Advocate
                 For the Opposite Party/s :       Mr. Shyam Kumar Singh, A.P.P.
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE PRABHAT KUMAR SINGH
                                       ORAL ORDER

4   27-02-2026                   Heard learned counsel for the petitioner and the State.

                                 2. Petitioner seeks regular bail in connection with

                   Dhanarua P. S. Case No. 264 of 2025 registered for the offence

                   punishable under Section 103(1) of the Bharatiya Nyaya

                   Sanhita.

                                 3. As per prosecution case, informant, Gyanati Devi,

                   alleged that her younger daughter was lured away by her son-in-

                   law about six months ago. On 26.04.2025 at about 3 PM, when

                   informant reached the house of in-laws of her daughter to meet

                   her, she found that her younger daughter was lying dead.

                   Informant alleged that this petitioner committed murder of her

                   daughter by strangulation.

                                 4. Learned counsel for the petitioner submits that

                   petitioner is innocent and has committed no offence. Informant
            Patna High Court CR. MISC. No.87134 of 2025(4) dt.27-02-2026
                                                        2/2




                      is not an eye witness to the occurrence and only suspicion has

                      been raised against this petitioner. As a matter of fact, deceased

                      committed suicide and as per post-mortem report, cause of death

                      is ‘Asphyxia due to hanging’. Charge has already been framed

                      and during trial, grandmother (Nani) of the deceased, has been

                      declared hostile, who stated that no one has killed her

                      granddaughter (Natini) (Annexure-P/1 to the supplementary

                      affidavit). Petitioner claims clean antecedent and is in custody

                      since 30.07.2025.

                                   5. However, learned A.P.P. for the State vehemently

                      opposed the bail application.

                                   6. Considering the nature of accusation, clean

                      antecedent, period of custody and the fact that charge has been

                      framed, this bail application is allowed. The petitioner, above

                      named, is directed to be released on bail on furnishing bail bond

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

                      amount each to the satisfaction of the learned Sub-Divisional

                      Judicial Magistrate, Mausaurhi, Patna in connection with

                      Dhanarua P. S. Case No. 264 of 2025.



                                            (Prabhat Kumar Singh, J)
Navya/-
U       T

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