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2026 Supreme(Online)(Pat) 3591

PATNA HIGH COURT
Prabhat Kumar Singh, J
Mamta Devi, Lalita Devi, Upendra Mehta, Gobind Mehta, Renu Devi, Jitu Jitendra Mehta – Appellant
Versus
The State of Bihar – Respondent
CRIMINAL MISCELLANEOUS No.81010 of 2025



Advocates:
For the Appellants/Petitioners: Mr. Arun
For the Respondents: Mr. Shailendra Kumar Singh, APP

The court upheld the gravity of dowry death allegations as justifiable grounds to deny anticipatory bail.

Headnote:In this judgment, the Court analyzed the laws relating to anticipatory bail, especially in the context of allegations surrounding dowry death under Sections 103(1), 80, 238, and 3(5) of the B.N.S. The petitioners asserted their innocence, claiming false implications; however, the gravity of the accusations, involving specific claims of torture leading to a victim's unnatural demise, remained central to the Court's determination. The Court highlighted that it is prudent to deny anticipatory bail given the strong evidentiary concerns regarding the petitioners' involvement, culminating in the rejection of their plea.

CORAM: HONOURABLE MR. JUSTICE PRABHAT KUMAR SINGH ORAL ORDER

3 15-01-2026 Heard learned counsel appearing on behalf of the petitioners and learned APP appearing on behalf of the State.

2. The petitioners apprehend their arrest in a case registered for the offence punishable under Sections 103(1), 80, 238 and 3(5) of the B.N.S. .

3. It is a case of dowry death. As per prosecution case, marriage of daughter of informant was solemnized with co- accused Raju Mehta about 5 years ago as per Hindu rites and rituals. It is alleged that after marriage, all the F.I.R. named accused persons, including these petitioners, tortured and harassed the victim for dowry and due to non-fulfillment of demand of dowry, all the accused persons killed the victim.

4. It is submitted by learned counsel appearing on behalf of the petitioners that petitioners are quite innocent and have committed no offence. Petitioners have falsely been implicated in this case merely because Petitioner Nos. 1 and 5 happen to be sister-in-law, Petitioner No. 2 happens to be mother-in-law Petitioner Nos. 3 and 6 happen to be brother-in- law of the deceased and Petitioner No. 4 happens to be distant relative of husband of the deceased. Petitioners are separate in mess and property and have got no concern with the affairs of the deceased and her husband. Petitioners claim clean antecedents.

5. On the other hand, learned A.P.P. for the State has vehemently opposed the prayer for grant of anticipatory bail to the petitioners and submitted that petitioners are named in the F.I.R. with specific accusation that they, along with other accused persons, used to torture and harass the victim for dowry and due to non-fulfillment of demand of dowry, all of them committed her murder. The deceased died unnatural death at her matrimonial house with seven years of marriage.

6. Considering the facts and circumstances of the case, specific and direct nature of accusation, gravity of offence and the fact that the deceased died unnatural death at her matrimonial house with seven years of marriage, the prayer for grant of anticipatory bail to the petitioners is rejected.

(Prabhat Kumar Singh, J)

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