Patna High Court
Munni DeviversusThe State of Bihar
- Decided
- Disposal
- BAIL GRANTED
- Bench
- PRABHAT KUMAR SINGH
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
- B.N.S., 2023 — s. 3(5), 482, 80(2)
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
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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
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