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Pramila Devi Vs The State of Bihar — Patna HC (2025) — LawSathi Research

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Patna HC
2025
Pramila Devi Vs The State of BiharPramila Devi v. The State of Bihar

Allowed¶¶22

Pramila Devi v. The State of Bihar

Patna HC27 Aug 2025CR. MISC./43212/2025

Case brief

AI extract

What is this about?

Patna High Court Criminal Miscellaneous No.43212 of 2025, order dated 27-08-2025 by Justice Chandra Prakash Singh; regular bail allowed to Pramila Devi (mother-in-law of deceased) in Mahnar P.S. Case No. 65 of 2024, Vaishali, under Sections 304B, 201 r/w Section 34 IPC (dowry death); prosecution allegation of killing informant's daughter over Rs. 2 lakh dowry demand; general and omnibus allegation against petitioner; co-accused already on anticipatory bail (Cr. Misc. No. 16047/2025, order dated 13.05.2025); petitioner in custody since 24.02.2025; bail-bond Rs. 20,000/- with two sureties; State opposed through A.P.P.

What did the court decide?

Regular bail: petitioner to be enlarged on furnishing bail-bond of Rs. 20,000/- with two sureties of the like amount each to the satisfaction of the learned Court concerned, Vaishali at Hajipur, in connection with Mahnar P.S. Case No. 65 of 2024.

Why is it important?

Considering the facts and circumstances of the case and the period of custody, the petitioner is directed to be enlarged on bail on furnishing a bail-bond of Rs. 20,000/- with two sureties of the like amount each to the satisfaction of the learned Court concerned, Vaishali at Hajipur, in connection with Mahnar P.S. Case No. 65 of 2024; the bail application is allowed. ¶¶21

What the court decided

AI extract

Outcome

Regular bail: petitioner to be enlarged on furnishing bail-bond of Rs. 20,000/- with two sureties of the like amount each to the satisfaction of the learned Court concerned, Vaishali at Hajipur, in connection with Mahnar P.S. Case No. 65 of 2024.

Issue for consideration

Whether the petitioner (mother-in-law of the deceased), arraigned in Mahnar P.S. Case No. 65 of 2024 under Sections 304B and 201 read with Section 34 IPC for an alleged dowry death, is entitled to regular bail.

Court's answer

Considering the facts and circumstances of the case and the period of custody, the petitioner is directed to be enlarged on bail on furnishing a bail-bond of Rs. 20,000/- with two sureties of the like amount each to the satisfaction of the learned Court concerned, Vaishali at Hajipur, in connection with Mahnar P.S. Case No. 65 of 2024; the bail application is allowed.

Detailed headnote1 paragraphs

BAIL — Regular bail granted. Patna High Court (Chandra Prakash Singh, J.) enlarged the petitioner, the mother-in-law of the deceased, on bail in Mahnar P.S. Case No. 65 of 2024 (Vaishali), registered under Sections 304B, 201 read with Section 34 IPC for an alleged dowry death arising from non-fulfilment of a demand of Rs. 2 lakh. Learned counsel had submitted there were general and omnibus allegations against the petitioner, that she neither demanded dowry nor tortured the deceased, that the co-accused had already obtained anticipatory bail from a Coordinate Bench vide order dated 13.05.2025 in Cr. Misc. No. 16047/2025, and that she was in custody since 24.02.2025; the A.P.P. opposed the petition. Considering the facts and circumstances and the period of custody, the Court directed release on a bail-bond of Rs. 20,000/- with two like sureties to the satisfaction of the learned Court concerned, Vaishali at Hajipur, and allowed the application (order dt. 27-08-2025).

A

IN THE HIGH COURT OF JUDICATURE AT PATNA CRIMINAL MISCELLANEOUS No.43212 of 2025

Arising Out of PS. Case No.-65 Year-2024 Thana- MAHNAR District- Vaishali

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

Pramila Devi Wife of Ramchandra Rai Resident of Village - Ishahakpur, P.S.Mahnar, District - Vaishali.

... ... Petitioner/s

Versus

The State of Bihar Bihar

... ... Opposite Party/s

====================================================== Appearance : For the Petitioner/s : Mr.Subodh Kumar For the Opposite Party/s : Mr.Anil Kumar Singh No. 1 ======================================================

CORAM: HONOURABLE MR. JUSTICE CHANDRA PRAKASH SINGH

ORAL ORDER

4 27-08-2025

Heard learned counsel for the petitioner and learned

A.P.P for the State.

2. The petitioner has preferred this application for grant of regular bail in connection with Mahnar P.S. Case No. 65 of 2024 dated 20.03.2024 registered for the offences punishable u/ss 304B, 201 read with Section 34 of the Indian Penal Code.

3. As per the prosecution case, the petitioner and the co-accused persons are alleged to have killed the informant's daughter due to non-fulfillment of demand of Rs. 2 lakh as dowry.

4. Learned counsel for the petitioner has submitted that the petitioner is innocent and has falsely been implicated in

Patna High Court CR. MISC. No.43212 of 2025(4) dt.27-08-2025 2/2

this case. There is general and omnibus allegation against the petitioner. The petitioner is the mother-in-law of the deceased and she has no concern with the alleged offence. The petitioner neither demanded any dowry nor tortured the deceased. The coaccused persons have already been granted anticipatory bail by a Coordinate Bench of this court vide order dated 13.05.2025 passed in Cr. Misc. No. 16047/2025. The petitioner has clean antecedent as stated in para 3 of the bail petition. The petitioner is in custody since 24.02.2025.

5. Learned A.P.P. for the State has vehemently opposed the bail petition of the petitioner.

6. Considering the aforesaid facts and circumstances of the case as well as the period of custody, the petitioner abovenamed, is directed to be enlarged on bail on furnishing bail-bond of Rs.20,000/- (Rupees Twenty Thousand) with two sureties of the like amount each to the satisfaction of learned Court concerned, Vaishali at Hajipur in connection with Mahnar P.S. Case No. 65 of 2024.

7. The application stands allowed.

(Chandra Prakash Singh, J)

Issues for consideration

1 issue framed by the court

AI extract

1.
Whether the petitioner (mother-in-law of the deceased), arraigned in Mahnar P.S. Case No. 65 of 2024 under Sections 304B and 201 read with Section 34 IPC for an alleged dowry death, is entitled to regular bail.¶¶15
The court held
Considering the facts and circumstances of the case and the period of custody, the petitioner is directed to be enlarged on bail on furnishing a bail-bond of Rs. 20,000/- with two sureties of the like amount each to the satisfaction of the learned Court concerned, Vaishali at Hajipur, in connection with Mahnar P.S. Case No. 65 of 2024; the bail application is allowed.ratio¶¶21

Cases cited

Colour shows how this judgement treated each authority

AI extract

Cr. Misc. No. 16047/2025Referred¶¶19

Statutes considered

3 provisions across 1 enactments

AI extract

Indian Penal Code304B¶¶15 201¶¶15 34¶¶15

Procedural history

How this case reached the court

AI extract

Prior proceeding
Regular bail application filed in connection with Mahnar P.S. Case No. 65 of 2024 dated 20.03.2024, registered for offences punishable under Sections 304B and 201 read with Section 34 of the Indian Penal Code.¶¶15
Prior proceeding
Co-accused persons were granted anticipatory bail by a Coordinate Bench of the Patna High Court vide order dated 13.05.2025 passed in Cr. Misc. No. 16047/2025 (as submitted by learned counsel for the petitioner).¶¶19
Prior proceeding
Petitioner in custody since 24.02.2025.¶¶19

Parties & counsel

AI extract

petitioner
Pramila Devi, wife of Ramchandra Rai, resident of Village Ishahakpur, P.S. Mahnar, District Vaishali¶¶4
Subodh Kumar
respondent
The State of Bihar¶¶7
Anil Kumar Singh

Coram

AI extract

Chandra Prakash Singhauthor¶¶10

Case details

As recorded by the court registry

Court: Patna HC
Decided on: 27 Aug 2025 · August
Registered: 26 Jun 2025
Case no.: CR. MISC./43212/2025
CNR: BRHC010459792025
Bench: Chandra Prakash Singh
Disposal: BAIL GRANTED
Case type: Criminal Miscellaneous

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Cite this judgement

Pramila Devi v. The State of Bihar, CR. MISC./43212/2025 (PAT), decided on 27 August 2025.

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

Cases cited1

Cr. Misc. No. 16047/2025Referred¶¶19

Open Authorities

Statutes3

Indian Penal Code304B · 201 · 34

View all statutes

Procedural history3

Regular bail application filed in connection with Mahnar P.S. Case No. 65 of 2024 dated 20.03.2024, registered for offences punishable under Sections 304B and 201 read with Section 34 of the Indian Penal Code.
Co-accused persons were granted anticipatory bail by a Coordinate Bench of the Patna High Court vide order dated 13.05.2025 passed in Cr. Misc. No. 16047/2025 (as submitted by learned counsel for the petitioner).

View full history

Bench / Coram

Chandra Prakash Singh

Parties & counsel