Dismissed¶24

Arjun Sah v. The State of Bihar

Bail – Rejection

Patna HC14 Jul 2026CR. MISC./18401/2026

Download

Case brief

AI extract

What is this about?

Arjun Sah v. The State of Bihar; Patna High Court; Criminal Miscellaneous No. 18401 of 2026; bail rejection; dowry death; Sections 80(2), 238, 3(5) BNS; Section ¾ Dowry Prohibition Act; Sripur P.S. Case No. 187 of 2025; District Gopalganj; death in matrimonial home 02.08.2025; custody since 27.11.2025; clean antecedents; Justice Arun Kumar Jha; decided 14-07-2026; direction to expedite trial.

What did the court decide?

None; the prayer for grant of bail was rejected, with a direction to the learned trial court to expedite and conclude the trial at the earliest. ¶24

Arjun Sah Vs The State of Bihar — Dowry and Cruelty | Patna HC (2026)

What the court decided

AI extract

Outcome

None; the prayer for grant of bail was rejected, with a direction to the learned trial court to expedite and conclude the trial at the earliest.

¶24

Issue for consideration

Whether the petitioner, Arjun Sah, should be enlarged on bail in connection with Sripur P.S. Case No. 187 of 2025, registered for the alleged offences under Sections 80(2), 238, 3(5) of BNS and Section ¾ of the Dowry Prohibition Act.

¶14

Court's answer

Having regard to the nature of the allegation that the petitioner caused the dowry death of his wife, the Court was not inclined to enlarge the petitioner on bail.

¶23

Ratio / Principle

The petitioner's prayer for grant of bail is rejected.

¶24

Key takeaways

The learned trial court is directed to expedite the trial and conclude the same at the earliest.ratio¶26

Detailed headnote1 paragraphs

Bail - Rejection - Alleged dowry death of wife. Patna High Court (Hon'ble Mr. Justice Arun Kumar Jha), in Criminal Miscellaneous No. 18401 of 2026 arising out of Sripur P.S. Case No. 187 of 2025, Thana Sripur, District Gopalganj, registered for the alleged offences under Sections 80(2), 238, 3(5) of BNS and Section ¾ of the Dowry Prohibition Act, declined to enlarge the petitioner-husband on bail. The deceased, married to the petitioner in 2021, went missing from her matrimonial home on 02.08.2025; the informant suspected that she was killed and her dead body burnt. Learned counsel for the petitioner pleaded innocence, asserting that the deceased complained of stomach pain, died en route to hospital, and that the case was false, a dowry-demand theory being unbelievable five years after marriage, and that the petitioner was in custody since 27.11.2025 with clean antecedents; the learned APP opposed, stressing that the death and the FIR were of the same day and that no treatment papers were annexed. Having regard to the nature of the allegation against the petitioner for causing the dowry death of his wife, the Court rejected the prayer for bail and directed the learned trial court to expedite the trial and conclude it at the earliest. Order dated 14-07-2026.

¶1

IN THE HIGH COURT OF JUDICATURE AT PATNA CRIMINAL MISCELLANEOUS No.18401 of 2026

¶2

Arising Out of PS. Case No.-187 Year-2025 Thana- SRIPUR District- Gopalganj

¶3

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

¶4

Arjun Sah, S/o Munnilal Sah, Resident of Village- Rajpur (Ganesh Dumar), PS- Sripur, District- Gopalganj

... ... Petitioner/s

Versus

The State of Bihar

... ... Opposite Party/s

¶9

====================================================== Appearance : For the Petitioner/s : Mr.Pankaj Kumar Dubey, Advocate For the Opposite Party/s : Mr.Akshay Lal Pandit, APP ======================================================

¶10

CORAM: HONOURABLE MR. JUSTICE ARUN KUMAR JHA ORAL ORDER

¶11

5 14-07-2026

¶12

Heard learned counsel for the petitioner and learned

¶13

APP for the State.

¶14

In the present case, the petitioner seeks bail in connection with Sripur P.S. Case No. 187 of 2025, registered for the alleged offence under Sections 80(2), 238, 3(5) of BNS and Section ¾ of Dowry Prohibition Act.

¶15

The petitioner was married with the daughter of the informant in the year 2021 and on 02.08.2025, the petitioner informed the informant that his daughter had gone missing from her matrimonial home. The informant showed his suspicion that his daughter was killed and her dead body was burnt.

¶16

The learned counsel for the petitioner submits that the petitioner is innocent and has been falsely implicated in this case. The true fact of the case is that on 01.08.2025, the

¶17

Patna High Court CR. MISC. No.18401 of 2026(5) dt.14-07-2026 2/3

¶18

deceased made complaint about pain in her stomach and she was treated in a government hospital. In the night, pain again started and when she was being taken to hospital for her treatment, she died on her way. The informant and her family members reached the matrimonial home of the deceased and the dead body was cremated in their presence. Thereafter, they filed the present false case. The learned counsel further submits that the marriage had been solemnized five years back and demand of dowry after five years and causing death of the daughter of the informant after five years is not believable. The learned counsel also submits that the petitioner is in custody since 27.11.2025 and is having clean antecedents.

¶19

The learned APP for the State vehemently opposes the submission made on behalf of the petitioner. The learned APP submits that the petitioner is the husband of the deceased and the death was caused in the matrimonial home of the daughter of the informant and there is no satisfactory explanation as the informant has stated in the written report that the death occurred on 02.08.2025 and the FIR was lodged on the same day. So the story of the petitioner fallen ill or being treated or died within 24 hours and the informant joining the cremation are not plausible. The learned APP further submits that no paper

¶20

Patna High Court CR. MISC. No.18401 of 2026(5) dt.14-07-2026 3/3

¶21

for treatment has been annexed.

¶22