Patna High Court

Niranjan KumarversusThe State of Bihar

Decided: 20 February 2026
Disposal: BAIL REJECTED
Bench: R P MISHRA

Holding

Bail was denied to the petitioner.

Summary

The petitioner, Niranjan Kumar, sought bail in a case (Ekangarsarai P.S. Case No. 230 of 2025) alleging his involvement in the murder of his wife, who allegedly died due to a dowry dispute. The prosecution alleged that the petitioner, along with co‑accused, strangled the deceased for non‑fulfilment of dowry demands, citing a post‑mortem report indicating asphyxia. The petitioner contended he was innocent, had no criminal record, and never demanded dowry, arguing the charges were vague and he had even informed the informant of his sister’s hospitalization. The State opposed bail, emphasizing the seriousness of the murder charge and the petitioner’s relationship to the victim, placing the burden on him to explain the death. The Court, considering the gravity of the offence and the specific allegations, refused bail, directing the trial court to expedite the trial and allowing the petitioner to renew his bail plea after six months if the trial is not concluded.

Issues considered

Whether bail should be granted to the accused under Sections 80(2) and 3(5) of the Bharatiya Nyaya Sanhita, 2023 in a murder case involving alleged dowry demand.

Legislation cited

Bharatiya Nyaya Sanhita, 2023 — s. 3(5), 80(2)

Subjects

bail
dowry death
murder
Bharatiya Nyaya Sanhita
criminal procedure
presumption of guilt
post‑mortem report

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.88490 of 2025
                  Arising Out of PS. Case No.-230 Year-2025 Thana- EKANGARSARAI District- Nalanda
                 ======================================================
                 Niranjan Kumar S/o Ramdyal Bind @ Ramsakal Bind R/o Village - Banke
                 Bigha, P.S - Ekangarsarai, District - Nalanda

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :     Mr. Shashi Chand Pandey, Advocate
                 For the Opposite Party/s :     Mr. Nand Kishore Prasad, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE RUDRA PRAKASH
                 MISHRA
                                       ORAL ORDER

3   20-02-2026                          Heard learned counsel for the petitioner, learned

                   APP for the State and perused the case diary.

                                2. The petitioner seeks bail in connection with

                   Ekangarsarai P.S. Case No. 230 of 2025, instituted for the

                   offences punishable under Sections 80(2) and 3(5) of the

                   Bharatiya Nyaya Sanhita, 2023.

                                3. The prosecution case, in short, is that sister of the

                   informant has been done to death by her husband and in-laws

                   for non-fulfillment of demand of dowry.

                                4. Learned counsel for the petitioner submits that the

                   petitioner is innocent and has falsely been implicated in the

                   present case. Charge-sheet has been submitted in this case.

                   Learned counsel for the petitioner also submitted that the
Patna High Court CR. MISC. No.88490 of 2025(3) dt.20-02-2026
                                            2/3




          petitioner is husband of the deceased. The allegation levelled

          against the petitioner is general and omnibus in nature. It is next

          submitted that the petitioner has never made any demand of

          dowry from the deceased. It is further submitted that the

          petitioner himself informed the informant that his sister has

          been admitted in the hospital. The petitioner is in custody since

          21.09.2025 and has got no criminal antecedent.

                       5. Learned APP for the State has vehemently opposed

          the prayer for grant of bail to the petitioner and submitted that

          there is specific allegation against the petitioner along with

          other co-accused persons of committing murder of informant’s

          sister for non-fulfillment of demand of dowry. It is further

          submitted that as per post-mortem report, cause of death has

          been opined as asphyxia due to strangulation. Further the

          petitioner is husband of the deceased and, therefore, onus lies

          upon him to explain the cause of death. Hence, the petitioner

          does not deserve the privilege of bail.

                       6. Considering the aforesaid facts and circumstances

          of the case, nature of accusation and the gravity of the offence,

          this Court is not inclined to grant bail to the petitioner.

                       7. The prayer is rejected. The trial Court is directed to

          expedite the Trial. However, if the trial is not concluded within a
             Patna High Court CR. MISC. No.88490 of 2025(3) dt.20-02-2026
                                                         3/3




                       period of six months from the date of receipt/production, the

                       petitioner will have liberty to renew his prayer for bail in the

                       Court below.



                                                                   (Rudra Prakash Mishra, J)
Rajorshi/-

U       T

Continue reading with your account

Checking your session…