Created by Fuzzy Cloud

Patna High Court

Munni DeviversusThe State of Bihar

Decided
Disposal
BAIL GRANTED

Holding

The Court granted anticipatory bail to the petitioners with specified conditions under Section 482 of the B.N.S., 2023.

Summary

The petitioners, who are the mother‑in‑law, sister‑in‑law and brother‑in‑law of a woman who died under suspicious circumstances, filed an application for anticipatory bail in a case registered under Sections 80(2) and 3(5) of the B.N.S., 2023 alleging dowry‑related cruelty and murder. The prosecution alleges that the deceased was strangulated by her husband and co‑accused, while the petitioners contend that the woman committed suicide and they have no involvement in the family dispute. The State and the informant opposed the bail. The Court examined the factual matrix and, considering the petitioners' lack of direct connection to the alleged offence, ordered that they be granted anticipatory bail provided they surrender within eight weeks, furnish a bail bond of Rs 10,000 with two sureties, and comply with conditions under Section 482 of the B.N.S., 2023. The order is subject to the satisfaction of the concerned Judicial Magistrate.

Issues considered

  • Whether anticipatory bail can be granted to the petitioners under Section 482 of the B.N.S., 2023 in a case alleging dowry‑related murder.
  • Whether the petitioners have any material participation in the alleged offence warranting denial of bail.

Legislation cited

Subjects

  • anticipatory bail
  • dowry death
  • suicide
  • Section 482
  • criminal procedure
  • bail conditions
  • murder
  • harassment

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.89721 of 2025
                 Arising Out of PS. Case No.-198 Year-2025 Thana- CHANPATIA District- West Champaran
                 ======================================================
           1.     Munni Devi W/o- Late Shankar Sah R/v- Miskar Toli Ps- Chanpatiya Dist-
                  West Champaran
           2.    Rekha Devi @ Rekha Kumari W/o- Satyam Kumar R/v- Miskar Toli Ps-
                 Chanpatiya Dist- West Champaran
           3.     Satyam Kumar S/o- Late Shankar Sah R/v- Miskar Toli Ps- Chanpatiya Dist-
                  West Champaran
                                                                           ... ... Petitioner/s
                                                  Versus
                 The State of Bihar
                                                                    ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioners     :       Mr.Brij Kishor Mishra
                 For the State           :       Mr.Rana Randhir Singh
                 For the Informant       :       Mr.Umesh Kumar Gupta
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE PRABHAT KUMAR SINGH
                                       ORAL ORDER

2   15-01-2026                    Heard learned counsel for the petitioners, learned

                   A.P.P. for the State and learned counsel for the informant.

                                2. The petitioners apprehend their arrest in a case,

                   registered for the offence under Sections 80(2), 3(5) of the

                   B.N.S., 2023.

                                3. As per prosecution case, daughter of informant was

                   married with co-accused Shivam Kumar and after the marriage,

                   she was subjected to cruelty and harassment by the accused

                   persons for dowry and ultimately, on 13.09.2025, she was killed

                   by strangulation.

                                4. Petitioner no. 1 is mother-in-law, petitioner no. 2 is

                   sister-in-law and petitioner no. 3 is brother-in-law of the

                   deceased. There is general and omnibus allegation. As a matter
           Patna High Court CR. MISC. No.89721 of 2025(2) dt.15-01-2026
                                                       2/2




                     of fact, the deceased committed suicide, as she was not happy

                     with her marital life. Thrust of the accusation is against husband

                     of the deceased, who is already in custody. Petitioners are

                     separate in mess and property and have got no concern with the

                     family affairs of deceased and her husband.

                                  5. Learned A.P.P. for the State and learned counsel for

                     the informant opposed the prayer for anticipatory bail of

                     petitioners.

                                  6. However, in the facts and circumstances of the

                     case, let the above named petitioners, in the event of

                     arrest/surrender within a period of eight weeks from today, be

                     enlarged on bail on furnishing bail-bonds of Rs. 10,000/- (ten

                     thousand) each with two sureties of the like amount each to the

                     satisfaction of learned J.M. 1st Class, Bettiah (West Champaran)

                     in connection with Chanpatiya P.S. Case No. 198 of 2025,

                     subject to condition as laid down under Section 482 of the

                     B.N.S.S., 2023.



                                                      (Prabhat Kumar Singh, J)
anay

U      T


Continue reading with your account

Sign in to read the full judgment. It’s free.

Sign in to read

Checking your session…

For a signed copy suitable for filing, refer to the court's website.