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Patna High Court

Geeta KumariversusThe State of Bihar

Decided
Disposal
BAIL GRANTED

Holding

The Court granted anticipatory bail to the petitioner, subject to conditions under Section 482(2) of the Bharatiya Nagarik Suraksha Sanhita, 2023.

Summary

Geeta Kumari, the sister‑in‑law of a woman who was allegedly murdered in a dowry dispute, was named as an accused in FIR No. 84 of 2025 under Sections 85, 103(1), 238 and 3(5) of the Bharatiya Nagarik Suraksha Sanhita, 2023. The FIR was lodged 17 years after the alleged crime and the informant later filed a petition retracting his statement. The petitioner contended that she had no specific allegation against her, no criminal antecedent, and was merely a named co‑accused in a general allegation. The State opposed the grant of anticipatory bail. Considering the lack of specific charge, the retraction of the informant’s statement, and the petitioner’s clean record, the Court inclined to grant anticipatory bail subject to conditions under Section 482(2) of the same Act.

Issues considered

  • Whether anticipatory bail should be granted to Geeta Kumari in view of the general allegations and the retraction of the informant’s statement.

Legislation cited

Subjects

  • anticipatory bail
  • dowry death
  • Bharatiya Nagarik Suraksha Sanhita
  • retraction of statement
  • sister‑in‑law
  • bail conditions

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.91833 of 2025
                     Arising Out of PS. Case No.-84 Year-2025 Thana- Rampur Chauram District- Arwal
                 ======================================================
                 Geeta Kumari Wife of Manish Kumar D/o Kaushlendra Singh, Resident of
                 Village - Nonia Bigha, P.S.- Arwal, District - Arwal (Wrongly written in FIR
                 village - Sarauti, P.S.- Rampur Chauram, District - Arwal).

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :        Mr.Ravindra Kumar, Adv
                 For the Opposite Party/s :        Mr.Vinod Shanker Modi, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE ALOK KUMAR SINHA
                                       ORAL ORDER

2   15-01-2026                     Heard learned counsel for the petitioner and learned

                   A.P.P. for the State.

                                2. The petitioner apprehends her arrest in connection

                   with Rampur Chauram P.S. Case No. 84 of 2025, registered for

                   the offence punishable under Sections 85/103(1)/238/3(5) of the

                   B.N.S., 2023.

                                3. The case of the prosecution, in short, as per the

                   informant is that he submitted a written application to Rampur

                   Chauram police station stating that he had married his daughter

                   to Mukesh Kumar in 2008 according to Hindu customs. He gave

                   money and gifts as dowry according to his means. His

                   daughter's husband and in-laws were demanding ten lakh rupees

                   from her and were pressuring her to give them the money. Upon
Patna High Court CR. MISC. No.91833 of 2025(2) dt.15-01-2026
                                            2/3




          receiving information from his daughter, they went and tried to

          reason with them, but they did not listen. Finally, his daughter

          was murdered by her husband Mukesh Kumar and her in-laws,

          including her father-in-law Kaushlendra Singh, mother-in-law

          Meena Devi, brother-in-law Sudhir Kumar, and sister-in-law

          Geeta Kumari, all acting together. When they went to inquire

          after receiving the information, people told them that his

          daughter had been taken to the hospital. After a considerable

          time, they received no further information. All of them

          conspired together and murdered his daughter.

                       4. Learned counsel for the petitioner submits that the

          petitioner is innocent and has committed no offence. The

          petitioner is married sister-in-law (nanad) of the deceased and

          has nothing to do with the allegations levelled against her. He

          further submits that the petitioner has no no criminal antecedent.

                       5. Learned A.P.P. for the State opposes the prayer of

          anticipatory bail.

                       6. The deceased daughter of the informant, namely,

          Sarita Kumari was married to Mukesh Kumar since 2008 and

          the FIR has been lodged after nearly 17 years on 02.09.2025

          alleging demand of dowry in which the petitioner who happens

          to be married sister-in-law has also been named as accused
              Patna High Court CR. MISC. No.91833 of 2025(2) dt.15-01-2026
                                                          3/3




                        person. Against the petitioner Geeta Kumari, there is no specific

                        allegation and in fact, there is general and omnibus allegation

                        against all accused persons including the petitioner. The

                        petitioner has no criminal antecedent. The informant is also said

                        to have retracted his statement by filing a petition dated

                        26.11.2025 before the learned CJM, Arwal. Considering the

                        aforesaid facts and circumstances of the present case, this Court

                        is inclined to grant privilege of anticipatory bail to the

                        petitioner.

                                      7. Let the petitioner, named above, in the event of her

                        arrest or surrender before the Court below within four weeks

                        from today, be released on bail on furnishing bail bond of

                        Rs.10,000/- (Ten thousand) with two sureties of the like amount

                        each to the satisfaction of the learned Chief Judicial Magistrate,

                        Arwal in connection with Rampur Chauram P.S. Case No. 84 of

                        2025, subject to the conditions laid down under section 482(2)

                        of the Bharatiya Nagarik Suraksha Sanhita, 2023.



                                                 (Alok Kumar Sinha, J)
kiran/-

U         T


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