Patna High Court
Priyaranjan Kumar Thakur @ Priya Ranjan KumarversusThe State of Bihar
- Decided
- Disposal
- BAIL REJECTED
- Bench
- SATYAVRAT VERMA
Holding
Bail was denied to the petitioner.
Summary
The petitioner, Priyaranjan Kumar Thakur, was arrested in connection with the alleged dowry death of his wife and sought bail. The FIR alleges that the petitioner demanded additional dowry, tortured the victim for non‑payment, and had an extramarital affair, culminating in the victim's death, which the prosecution claims was a homicide. The petitioner contended that he has a clean record, the informant was not an eye‑witness, no prior dowry complaints were filed during the six‑year marriage, and the death was a suicide, also noting that the mother‑in‑law had earlier obtained anticipatory bail. The State opposed bail, emphasizing the statutory presumption against the husband in dowry death cases and arguing that the allegations, though not eyewitness‑based, establish a prima facie case. The court, after considering the submissions, held that the presumption and seriousness of the charges outweighed the bail plea and consequently denied bail.
Issues considered
- Whether the petitioner is entitled to bail despite the presumption under Section 304B of the IPC in dowry death cases
- Whether the allegations in the FIR, without an eye‑witness, are sufficient to deny bail
- Whether the prior anticipatory bail granted to the mother‑in‑law is relevant to the petitioner's bail application
Legislation cited
- Dowry Prohibition Act — s. 3
- Indian Penal Code — s. 304B, 34
Subjects
- dowry death
- bail
- IPC 304B
- Section 34 IPC
- Dowry Prohibition Act
- presumption of guilt
- anticipatory bail
Judgment
IN THE HIGH COURT OF JUDICATURE AT PATNA
CRIMINAL MISCELLANEOUS No.88635 of 2025
Arising Out of PS. Case No.-62 Year-2024 Thana- SARAIYA District- Muzaffarpur
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Priyaranjan Kumar Thakur @ Priya Ranjan Kumar S/o- Late Navalkishor
Thakur Resident of Village - Siuri Aima, Ps- Saraiya Dist- Muzaffarpur
... ... Petitioner/s
Versus
The State of Bihar
... ... Opposite Party/s
======================================================
Appearance :
For the Petitioner/s : Mr. Manoj Kumar, Advocate
For the Opposite Party/s : Mr. Binod Kumar, APP
======================================================
CORAM: HONOURABLE MR. JUSTICE SATYAVRAT VERMA
ORAL ORDER
2 11-03-2026 Heard learned counsel for the petitioner and learned
APP for the State.
2. The petitioner seeks bail in a case registered for the
offences punishable under Sections 304B and 34 of the Indian
Penal Code and Sections ¾ of the Dowry Prohibition Act.
3. Learned counsel for the petitioner submits that
petitioner is a person with clean antecedent and is in custody
since 11.07.2025 and the informant alleges that his daughter was
married to the petitioner, after marriage, the accused persons
started demanding Rs.2,00,000/- by way of additional dowry,
further the petitioner was demanding Rs.2,00,000/- for running
the school and used to torture the victim on account of non-
fulfillment of the demand, next alleges that his daughter
disclosed that petitioner was having extra an marital affair with
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Kajal Kumari and wanted to marry her. It is next alleged that on
29.01.2024 the informant received an information that his
daughter has been killed and her dead body is lying in the
house, accordingly, he reached the place of occurrence with the
police and saw the house locked, thereafter, they entered the
house and saw the dead body of his daughter lying on a bed
with mark of scratch on her neck and blood was oozing from her
mouth, thereafter, the dead body was sent for post mortem and
after post mortem, the dead body was handed over to the
informant on 30.10.2024 and the same was cremated.
4. Learned counsel for the petitioner submits that
petitioner being husband 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 informant is not an eye-witness to the occurrence.
It is next submitted that the marriage was six years old and in
these six years, no case ever came to be instituted either by the
deceased or the informant alleging demand of dowry and torture
on account of non-fulfillment of the demand. It is next
submitted that the deceased committed suicide. It is further
submitted that Gulabiya Devi, mother-in-law of the deceased,
had approached this Court seeking anticipatory bail by filing
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Criminal Miscellaneous No.51838 of 2024 and the same came
to be allowed by an order dated 23.09.2024.
5. The learned APP opposes the bail application and
submits that case of petitioner is not at parity with the case of
Gulabiya Devi. It is also submitted that the death took place
within seven years of marriage, as such, presumption of law is
also against the accused. It is next submitted that from perusal
of the allegations, as alleged in the FIR, it would manifest that
the informant alleges that he along with the police force reached
the place of occurrence and found the door locked and no one
was present in the house, as such, the door was broken and the
dead body was seen lying on a bed with mark of injuries. It is
also submitted that there is specific allegation against the
petitioner that he was having an extra marital relation with a
woman with whom he intended to marry. The learned APP fairly
submits that no doubt informant is not an eye-witness to the
occurrence nor any case came to be instituted in six years of
marriage but then what is not in dispute rather stands admitted is
that the deceased died but then whether she was killed or
committed suicide are an aspect of trial. It is also submitted that
it is the prime responsibility of the husband to ensure the well
being of his wife and even if the deceased committed suicide
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then it was petitioner who made conditions conducive for the
victim to take the extreme steps of ending her life.
6. Considering the submissions made by the learned
APP, the Court is not inclined to release the petitioner on bail.
Accordingly, the prayer for grant of bail to the petitioner is
hereby rejected in connection with Saraiya P.S. Case No.62 of
2024, pending in the court of learned Sub-Divisional Judicial
Magistrate, West, Muzaffarpur.
(Satyavrat Verma, J)
Sanjay/-
U T
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