Vikram Ram Vs The State of Bihar — Dowry and Cruelty | Patna HC (2026)

Vikram Ram Vs The State of Bihar — Dowry and Cruelty | Patna HC (2026)

What the court decided

AI extract

Outcome

Anticipatory bail: petitioner directed to be released on bail in the event of arrest or surrender before the learned Sub Divisional Judicial Magistrate, Rosera within four weeks, on a bail bond of Rs.10,000/- with two sureties of the like amount each, subject to conditions under Section 438(2) CrPC / Section 482(2) BNSS.

Issue for consideration

Whether the petitioner, named in Complaint Case No.120 of 2024 (offences under Section 498-A IPC and Sections 3 and 4 of the Dowry Prohibition Act) and apprehending arrest, is entitled to anticipatory bail. +1 more

Court's answer

In the event of arrest or surrender before the court below within four weeks, the petitioner is 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 the learned Sub Divisional Judicial Magistrate, Rosera, subject to the conditions under Section 438(2) CrPC / Section 482(2) BNSS.

Ratio / Principle

Taking note that the alleged dowry demand was very much general and omnibus against the petitioner, coupled with the fact that the complaint in issue is not supported by affidavit, the court granted anticipatory bail.

Detailed headnote1 paragraphs

Anticipatory Bail – Section 438 CrPC / Section 482 BNSS – Complaint under Section 498-A IPC and Sections 3 and 4 of the Dowry Prohibition Act (Complaint Case No.120 of 2024, P.S. Rosera, Samastipur; T.R. No.2473 of 2024) – Alleged dowry demand of one motorcycle and Rs.50,000/- held to be very much general and omnibus against the petitioner and his family members – Complaint not supported by affidavit, a point urged under Section 175(3) BNSS with reliance on Priyanka Srivastava v. State of Uttar Pradesh, (2015) 6 SCC 287 – Taking note of these facts, the Court directed release of the petitioner in the event of arrest or surrender within four weeks on a bail bond of Rs.10,000/- with two sureties of the like amount each, subject to conditions under Section 438(2) CrPC / Section 482(2) BNSS.

IN THE HIGH COURT OF JUDICATURE AT PATNA CRIMINAL MISCELLANEOUS No.29971 of 2026

Arising Out of PS. Case No.-120 Year-2024 Thana- COMPLAINT CASE - ROSERA District- Samastipur

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

Vikram Ram, S/o Sri Umesh Ram, R/o Village – Shasan, Ward No. 10, P.S. -Hasanpur, District - Samastipur

... ... Petitioner

Versus

The State of Bihar

Kanchan Kumari, W/o Vikram Ram, At present Address - Kanchan Kumari, D/o Ashok Ram, R/o Village - Maranchi, Indrapath, P.S. - Hasanpur, District - Samastipur

... ... Opposite Parties

====================================================== Appearance : For the Petitioner/s : Mr. Hriday Kant Mishra, Advocate For the Opposite Party/s : Md. Nazir Ansari, APP ======================================================

CORAM: HONOURABLE MR. JUSTICE CHANDRA SHEKHAR JHA ORAL ORDER

2 11-05-2026

Heard learned counsel for the petitioner and

learned Additional Public Prosecutor for the State.

The accused/petitioner is named in the

complaint and apprehending his arrest in connection with

Complaint Case No.120 of 2024 in which cognizance has been taken for the offences punishable 498-A of the Indian Penal Code and Sections 3 and 4 of the Dowry Prohibition Act.

The complainant Kanchan Kumari raised allegation through her complaint petition that petitioner

being husband along with his family members committed

Patna High Court CR. MISC. No.29971 of 2026(2) dt.11-05-2026 2/3

mental and physical cruelty upon her due to non-fulfilment of demand of dowry as raised for one motorcycle and cash of Rs.50,000/-.

It is submitted by learned counsel appearing for the petitioner that the complaint in issue is not supported by affidavit, which is otherwise mandatory in view of Section 175(3) of the BNSS. In support of this submission, learned counsel has relied upon legal report of Hon’ble Supreme Court as available through Priyanka Srivastava v. State of Uttar Pradesh [(2015) 6 SCC 287]. It is pointed out that due to this legal reason, the allegation as raised through complaint petition cannot be taken into consideration. While concluding argument, it is submitted that the allegation qua demanding dowry, as mentioned aforesaid, is appearing very much general and omnibus against petitioner and other family members.

Learned APP opposed the prayer for

anticipatory bail of the petitioner.

In view of aforesaid factual submissions and

by taking note of fact, as the dowry demand, as mentioned

Patna High Court CR. MISC. No.29971 of 2026(2) dt.11-05-2026 3/3

aforesaid, is appearing very much general and omnibus against petitioner, coupled with the fact that complaint in issue is not supported by affidavit, as discussed aforesaid, accordingly, the petitioner, above-named, in the event of his arrest or surrender in the court below within a period of four weeks from today, is directed to be released on bail on furnishing bail bond of Rs.10,000/- (Rupees Ten Thousand) with two sureties of the like amount each to the satisfaction of the learned Sub Divisional Judicial Magistrate, Rosera in connection with Complaint Case No.120 of 2024, T.R. No.2473 of 2024, subject to the conditions as laid down under Section 438(2) of the Code of Criminal Procedure (in short ‘CrPC’)/under Section 482(2) of the Bhartiya Nagrik Suraksha Sanhita, 2023 (in short ‘BNSS’).

(Chandra Shekhar Jha, J.)

Sanjeet/-

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