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Dev Narain Rai Vs The State of Bihar — Dowry and Cruelty | Patna HC (2025)

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Patna HC
2025
Dev Narain Rai Vs The State of BiharDev Narain Rai v. The State of Bihar

Allowed¶21

Dev Narain Rai v. The State of Bihar

Patna HC19 Nov 2025CR. MISC./24409/2025

Case brief

AI extract

What is this about?

Patna High Court anticipatory bail order dated 19-11-2025 by Justice Nawneet Kumar Pandey in Criminal Miscellaneous No.24409 of 2025 arising out of Samastipur Complaint Case No. 2324 of 2023 (S.498A IPC); petitioner Dev Narain Rai granted conditional arrest/surrender bail within four weeks before SDJM Samastipur with Rs. 10,000/- bail bond and two like sureties subject to S.438(2) Cr.P.C./S.482(2) B.N.S. conditions; dowry-torture and ouster allegations after 2001 marriage; complainant Neelam Devi; counsel for petitioner Bijay Bhushan Prasad and Rani Shashi Bharti; Parmanand Kumar for Opposite Party/s.

What did the court decide?

Conditional anticipatory bail — release upon arrest/surrender within four weeks before the court below on a bail bond of Rs. 10,000/- with two sureties of the like amount each to the satisfaction of learned Sub Divisional Judicial Magistrate, Samastipur, subject to conditions u/S 438(2) Cr.P.C./482(2) B.N.S.

Why is it important?

Anticipatory bail granted: petitioner, in the event of arrest or surrender within four weeks before the court below, to be released on bail on furnishing a bail bond of Rs. 10,000/- with two sureties of the like amount each to the satisfaction of learned Sub Divisional Judicial Magistrate, Samastipur in connection with Complaint Case No. 2324 of 2023, subject to the conditions laid down u/S 438(2) of the Cr.P.C./482(2) of the B.N.S. ¶21

What the court decided

AI extract

Outcome

Conditional anticipatory bail — release upon arrest/surrender within four weeks before the court below on a bail bond of Rs. 10,000/- with two sureties of the like amount each to the satisfaction of learned Sub Divisional Judicial Magistrate, Samastipur, subject to conditions u/S 438(2) Cr.P.C./482(2) B.N.S.

Issue for consideration

Whether the petitioner, apprehending arrest in Complaint Case No. 2324 of 2023 (offence punishable under Section-498A IPC), should be released on anticipatory bail.

Court's answer

Anticipatory bail granted: petitioner, in the event of arrest or surrender within four weeks before the court below, to be released on bail on furnishing a bail bond of Rs. 10,000/- with two sureties of the like amount each to the satisfaction of learned Sub Divisional Judicial Magistrate, Samastipur in connection with Complaint Case No. 2324 of 2023, subject to the conditions laid down u/S 438(2) of the Cr.P.C./482(2) of the B.N.S.

Detailed headnote1 paragraphs

ANTICIPATORY BAIL — Patna High Court (Nawneet Kumar Pandey, J), Criminal Miscellaneous No.24409 of 2025, order dt. 19-11-2025 arising out of Samastipur Complaint Case No. 2324 of 2023 (Section-498A IPC): petitioner Dev Narain Rai, who apprehended arrest in a dowry-related complaint alleging torture and ouster following his 2001 marriage (counsel contending the allegation surfaced 22 years after marriage and that the complainant resides separately, with a house built for her by the petitioner), was permitted, in the event of arrest or surrender within four weeks before the court below, release 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 Sub Divisional Judicial Magistrate, Samastipur, subject to conditions laid down u/S 438(2) of the Cr.P.C./482(2) of the B.N.S.

A

IN THE HIGH COURT OF JUDICATURE AT PATNA CRIMINAL MISCELLANEOUS No.24409 of 2025

Arising Out of PS. Case No.-2324 Year-2023 Thana- SAMASTIPUR COMPLAINT CASE District- Samastipur

======================================================

Dev Narain Rai S/o Late Ramdev Ray Resident of village- Mudewa, P.S.Muffasil, Dist- Samastipur

... ... Petitioner/s

Versus

The State of Bihar Bihar

Neelam Devi W/O Amarnath Paswan, R/O Singhia Bujurg, W. No. 11, P.S. Bibhutipur, District - Samastipur

... ... Opposite Party/s

====================================================== Appearance : For the Petitioner/s : Mr.Bijay Bhushan Prasad, Adv. Rani Shashi Bharti, Adv. For the Opposite Party/s : Mr.Parmanand Kumar ====================================================== CORAM: HONOURABLE MR. JUSTICE NAWNEET KUMAR PANDEY

ORAL ORDER

4 19-11-2025

Heard learned counsel for the petitioner and learned

APP for the State.

The petitioner apprehends his arrest in connection with Complaint Case No. 2324 of 2023 registered for the offence punishable under Section-498A of the Indian Penal Code.

Allegedly, the complainant was married with the petitioner in 2001 and two children were born out from the wedlock of the petitioner. It is alleged that the petitioner and other accused persons started torturing her in different ways for fulfillment of demand of dowry and ultimately, she was ousted

Patna High Court CR. MISC. No.24409 of 2025(4) dt.19-11-2025 2/2

from matrimonial home.

Learned counsel for the petitioner has submitted that the complainant has filed this case after 22 years of the marriage levelling allegation of demand of dowry, which is unbelievable prima facie. As a matter of fact, she was living in relationship with one Amarnath Paswan and it is the reason that she is not residing with the petitioner. The petitioner admittedly built a house separately for her, in which, she is residing.

On the other hand, learned counsel appearing for the State has opposed the prayer for anticipatory bail.

Considering the aforesaid facts and circumstances, let the petitioner named above, in the event of arrest/surrender within four weeks before the court below 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 learned Sub Divisional Judicial Magistrate, Samastipur in connection with Complaint Case No. 2324 of 2023 subject to the conditions as laid down u/S 438(2) of the Cr.P.C./482(2) of the B.N.S.

(Nawneet Kumar Pandey, J)

A.K.V.//- U T

Issues for consideration

1 issue framed by the court

AI extract

1.
Whether the petitioner, apprehending arrest in Complaint Case No. 2324 of 2023 (offence punishable under Section-498A IPC), should be released on anticipatory bail.¶15
The court held
Anticipatory bail granted: petitioner, in the event of arrest or surrender within four weeks before the court below, to be released on bail on furnishing a bail bond of Rs. 10,000/- with two sureties of the like amount each to the satisfaction of learned Sub Divisional Judicial Magistrate, Samastipur in connection with Complaint Case No. 2324 of 2023, subject to the conditions laid down u/S 438(2) of the Cr.P.C./482(2) of the B.N.S.ratio¶21

Statutes considered

3 provisions across 3 enactments

AI extract

Indian Penal Code498A¶15
Cr.P.C.438(2)¶21
B.N.S.482(2)¶21

Procedural history

How this case reached the court

AI extract

Prior proceeding
Complaint Case No. 2324 of 2023 registered at PS Samastipur (complaint case), District Samastipur.¶2
Prior proceeding
Petitioner apprehends arrest in Complaint Case No. 2324 of 2023 for offence punishable under Section-498A IPC; this application seeks anticipatory bail.¶15
Prior proceeding
Alleged background: complainant married petitioner in 2001, two children born, alleged torture for fulfilment of dowry demand and ultimate ouster from matrimonial home.¶16

Parties & counsel

AI extract

petitioner
Dev Narain Rai¶4
Bijay Bhushan Prasad, Rani Shashi Bharti
respondent
The State of Bihar¶7
Parmanand Kumar
respondent
Neelam Devi¶8

Coram

AI extract

Nawneet Kumar Pandeyauthor¶10

Case details

As recorded by the court registry

Court: Patna HC
Decided on: 19 Nov 2025 · November
Registered: 10 Apr 2025
Case no.: CR. MISC./24409/2025
CNR: BRHC010330422025
Topic: Dowry and Cruelty
Bench: Nawneet Kumar Pandey
Disposal: BAIL GRANTED
Case type: CRIMINAL MISCELLANEOUS

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Cite this judgement

Dev Narain Rai v. The State of Bihar, CR. MISC./24409/2025 (PAT), decided on 19 November 2025.

The Patna High Court publishes no neutral citation for this judgement — cite it by case number and date of decision.

Statutes3

Indian Penal Code498A
Cr.P.C.438(2)
B.N.S.482(2)

View all statutes

Procedural history3

Complaint Case No. 2324 of 2023 registered at PS Samastipur (complaint case), District Samastipur.
Petitioner apprehends arrest in Complaint Case No. 2324 of 2023 for offence punishable under Section-498A IPC; this application seeks anticipatory bail.

View full history

Bench / Coram

Nawneet Kumar Pandey

Parties & counsel