Patna High Court

Krishna Paswan @ Krishn PaswanversusThe State of Bihar

Decided: 8 January 2026
Disposal: ALLOWED
Bench: ASHOK KUMAR PANDEY

Holding

The Court granted bail to the petitioners.

Summary

The petitioners, Krishna Paswan and Rukmini Devi, who are the father‑in‑law and mother‑in‑law of the deceased Rinku Devi, applied for bail in a case registered under Sections 80, 238 and 3(5) of the B.N.S., 2023 for alleged murder. The prosecution alleged that the petitioners, along with others, killed the deceased over a dowry dispute involving a bike, cash and jewellery. The petitioners contended that they are innocent, have no criminal antecedents, and have been falsely implicated, having been in judicial custody since 11‑09‑2025. The State opposed the bail, arguing that the seriousness of the charges warranted continued detention. After hearing both sides, the Court considered the lack of specific evidence against the petitioners and their clean record, and decided to enlarge them on bail. The bail was ordered on the condition of a Rs.10,000 bond each with two sureties.

Issues considered

Whether bail should be granted to the petitioners under Sections 80, 238 and 3(5) of the B.N.S., 2023 despite the serious nature of the alleged offence
Whether the allegations against the petitioners constitute sufficient ground to deny bail

Legislation cited

B.N.S., 2023 — s. 238, 3(5), 80

Subjects

bail
dowry death
cruelty
Section 80 B.N.S.
Section 238 B.N.S.
Section 3(5) B.N.S.
criminal procedure
Patna High Court

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.88891 of 2025
                        Arising Out of PS. Case No.-95 Year-2025 Thana- BHADAUR District- Patna
                 ======================================================
           1.     Krishna Paswan @ Krishn Paswan S/O Parbhu Paswan Resident of Village-
                  Chakdaulat, P.S- Bhadaur, District- Patna.
           2.     Rukmini Devi @ Sharmili Devi W/O Sri Krishna Paswan @ Krishn Paswan
                  R/O Village- Chakdaulat, P.S- Bhadaur, Distt.- Patna.
                                                                               ... ... Petitioner/s
                                                   Versus
                 The State of Bihar
                                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :       Mr. Anil Kumar Singh, Advocate
                 For the Opposite Party/s :       Mr. Rajendra Nath Jha, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE ASHOK KUMAR PANDEY
                                       ORAL ORDER
2   08-01-2026                   Heard learned counsel for the petitioners and learned

                   APP for the State.

                                2. The petitioners have prayed for bail in connection

                   with Bhadaur P.S. Case No. 95 of 2025 registered for the offence

                   punishable under Sections 80, 238, 3(5) of the B.N.S., 2023.

                                3. The case of the prosecution in short is that Rinku

                   Devi (deceased) was married to one Rahul Paswan. On

                   09.09.2025, a phone call was received that the deceased had been

                   killed. When the informant reached the matrimonial house of the

                   deceased, he found that the in-laws had fled away. It is further

                   alleged that the marriage of the deceased was solemnized in the

                   year 2022, and she was being subjected to cruelty on account of

                   non-fulfillment of dowry demand of a bike and some cash and

                   jewellery. It is alleged that the petitioner along with others, killed
          Patna High Court CR. MISC. No.88891 of 2025(2) dt.08-01-2026
                                                      2/2




                    the deceased.

                                 4. Learned counsel appearing on behalf of the

                    petitioners has submitted that petitioners are innocent and have

                    committed no offence. They have been falsely implicated in this

                    case. Learned counsel for the petitioners submits that the

                    petitioners are father-in-law and mother-in-law of the deceased

                    and the nature of allegation is general and omnibus. It has also

                    been submitted that a statement has been made in para 3 of the

                    petition that petitioners have no criminal antecedent and they are

                    languishing in judicial custody since 11.09.2025.

                                 5. The application for bail is opposed by learned APP

                    for the State.

                                 6. Having heard learned counsel for the parties and

                    considering the facts and circumstances of the case, this Court is

                    inclined to enlarge the petitioners on bail. The above named

                    petitioners are directed to be enlarged on bail on furnishing bail

                    bond of Rs. 10,000/- (Rs. ten thousand only) each with two

                    sureties of the like amount each to the satisfaction of the learned

                    Judiciail Magistrate, 1st Class, Barh, Patna in connection with

                    Bhadaur P.S. Case No. 95 of 2025.



                                                   (Ashok Kumar Pandey, J)
Sudhanshu/-
U      T

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