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2026 Supreme(Online)(Pat) 3700

PATNA HIGH COURT
Prabhat Kumar Singh, J
Sanjan Devi @ Sanjan Kumari – Appellant
Versus
The State of Bihar – Respondent
CRIMINAL MISCELLANEOUS No.1091 of 2026



Advocates:
For the Appellants/Petitioners: Mr. Amarnath Jha
For the Respondents: Mr. Madhura Nand Jha

Accusations lacking specificity and insufficient evidence warrant anticipatory bail.

Headnote:The petitioner, apprehending arrest for offences under Sections 80(2), 238, and 3(5) of the B.N.S., claimed innocence and lack of involvement in the alleged dowry-related murder case. The court found the accusations against the petitioner to be general and omnibus, granted anticipatory bail, subject to conditions. The matter hinged on the purported relationships and lack of direct evidence against the petitioner.

Result: Petitioner's anticipatory bail granted on stipulated conditions.

CORAM: HONOURABLE MR. JUSTICE PRABHAT KUMAR SINGH ORAL ORDER

2 28-01-2026 Heard learned counsel appearing on behalf of the petitioner and learned APP appearing on behalf of the State.

2. The petitioner apprehends her arrest in a case registered for the offence punishable under Sections 80(2), 238 and 3(5) of the B.N.S. .

3. As per prosecution case, marriage of daughter of informant was solemnized with co-accused Manjay Kumar about three years ago. It is alleged that after some time of marriage, all the F.I.R. named accused persons started demanding dowry and due to non-fulfillment of demand of dowry, they committed torture and harassment with the victim. It is further alleged that this petitioner had illicit relations with husband of daughter of informant and on 09.06.2025 at about 4 PM, daughter of informant caught this petitioner along with her husband in an objectionable position and in retaliation, all the F.I.R. named accused persons, including this petitioner, committed murder of daughter of informant.

4. It is submitted by learned counsel appearing on behalf of the petitioner that petitioner is quite innocent and has committed no offence. Petitioner is not a family members of the deceased and she has falsely been implicated in this case merely on suspicion that she had illicit relations with husband of the deceased. Allegation of finding this petitioner with husband of the deceased in an objectionable condition is absolutely fictitious and she has nothing to do with the deceased or her husband. Petitioner is merely neighbour of husband of the deceased. During investigation, none of the witnesses have even raised suspicion against this petitioner. Moreover, thrust of accusation is against husband of the deceased who is already in custody. Petitioner is a lady and claims clean antecedents.

5. Learned A.P.P. for the State has vehemently opposed the prayer for grant of anticipatory bail to the petitioner.

6. Considering the facts and circumstances of the case, general and omnibus nature of accusation and clean antecedents of the petitioner, the prayer for grant of anticipatory bail to the petitioner is allowed.

7. Accordingly, in the event of arrest/surrender within a period of eight weeks from today, let the above named petitioner be enlarged on bail on furnishing bail-bond of Rs. 10,000/- (ten thousand) with two sureties of the like amount each to the satisfaction of learned C.J.M., Madhepura in connection with Madhepura (Ghailrah O.P.) P.S. Case No. 645 of 2025, subject to condition as laid down under Section 482(2)

of the B.N.S. S..

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