Patna High Court
Palho Kumari @ Palho DeviversusThe State of Bihar
- Decided
- Disposal
- DISMISSED
- Bench
- SANDEEP KUMAR
Holding
The court held that bail could not be granted and dismissed the application.
Summary
The petitioner, Palho Kumari, filed a regular bail application in the Patna High Court in connection with a criminal case (Sessions Trial No. 334 of 2025) arising from a murder alleged under Sections 103(1) and 238 of the Indian Penal Code. The prosecution alleged that unknown criminals killed the deceased, but investigation later revealed that the petitioner, the wife of the deceased, conspired with a man named Mohsin and murdered her husband. The petitioner had been in custody since 11 May 2025. The primary issue before the court was whether bail could be granted given the seriousness of the alleged offences and the alleged conspiracy. The court examined the nature of the charges, the evidence of pre‑meditated murder and conspiracy, and the risk of tampering with evidence or influencing witnesses. Considering the gravity of the allegations, the court was not inclined to grant bail. Consequently, the bail application was dismissed.
Issues considered
- Whether regular bail can be granted to the petitioner under Sections 103(1) and 238 of the Indian Penal Code given the seriousness of the alleged murder and conspiracy
- Whether the petitioner poses a risk of tampering with evidence or influencing witnesses
Legislation cited
- Indian Penal Code — s. 103(1), 238
Subjects
- regular bail
- murder
- conspiracy
- Indian Penal Code
- Section 103
- Section 238
- high court
- bail denial
Judgment
IN THE HIGH COURT OF JUDICATURE AT PATNA
CRIMINAL MISCELLANEOUS No.88263 of 2025
Arising Out of PS. Case No.-142 Year-2025 Thana- KUDRA District- Kaimur (Bhabua)
======================================================
Palho Kumari @ Palho Devi W/o Late Prakash Urawaon R/o Village- Barri
Nawatoli, P.S- Puso, Dist- Gumala (Jharkhand).
... ... Petitioner/s
Versus
The State of Bihar Bihar
... ... Opposite Party/s
======================================================
Appearance :
For the Petitioner/s : Mr.Rajani Kant Pandey
For the Opposite Party/s : Mr.Satyendra Prasad
======================================================
CORAM: HONOURABLE MR. JUSTICE SANDEEP KUMAR
ORAL ORDER
4 19-03-2026 Heard the parties.
2. The petitioner seeks regular bail in connection with
Sessions Trial No. 334 of 2025 arising out of Kudra P.S. Case
No. 142 of 2025 registered for the offence under Sections
103(1)/238 of the BNS.
3. As per the prosecution case, unknown criminals are
said to have killed the deceased.
4. The petitioner is in custody since 11.05.2025.
5. During investigation, it has come that the wife of
the deceased, who is the petitioner, was in relationship with one
Mohsin and after hatching conspiracy against her husband, she
has killed her husband.
6. Considering the serious allegations levelled against
the petitioner, this Court is not inclined to grant bail to the
Patna High Court CR. MISC. No.88263 of 2025(4) dt.19-03-2026
2/2
petitioner.
7. Accordingly, this application is dismissed.
(Sandeep Kumar, J)
Vikas/-
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