Allowed¶26

Manik v. The State of Bihar

Patna HC21 Jan 2026CR. MISC./35507/2025

Case brief

AI extract

What is this about?

Manik v. The State of Bihar & Anr., Patna High Court, Criminal Miscellaneous No. 35507 of 2025, order dated 21-01-2026, Chandra Shekhar Jha, J. Anticipatory bail granted in a dowry-cruelty complaint case (Sections 498A, 379, 120B IPC; Section 3/4 D.P. Act; Complaint Case No. 1562 of 2023, SDJM Gaya); allegations of mental and physical assault held general and omnibus; bail bond Rs. 10,000/- with two like sureties; subject to Section 482(2) BNSS conditions; alleged dowry demand of Rs. 40 lakh noted from informant's side.

What did the court decide?

Anticipatory bail: petitioner to be released on bail in the event of arrest or surrender before the court below within four weeks, on bail bond of Rs. 10,000/- with two sureties of the like amount each, to the satisfaction of the learned SDJM, Gaya, subject to conditions under Section 482(2) of BNSS.

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

What the court decided

AI extract

Outcome

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Issue for consideration

Whether the petitioner, named in Complaint Case No. 1562 of 2023 (offences punishable under Sections 498A, 379, 120B of IPC and Section 3/4 of the D.P. Act) and apprehending arrest, should be released on anticipatory bail.

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Court's answer

The Court took note that the allegation qua commission of mental and physical assault appears very much general and omnibus in nature, and on that factual basis proceeded to allow the prayer for bail.

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Ratio / Principle

Petitioner directed to be released on bail in the event of his arrest or surrender before the court below within a period of four weeks, on furnishing bail bond of Rs. 10,000/- with two sureties of the like amount each, to the satisfaction of the learned SDJM, Gaya, subject to the conditions laid down under Section 482(2) of BNSS.

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Detailed headnote1 paragraphs

Anticipatory bail allowed (Patna High Court, Chandra Shekhar Jha, J., order dated 21-01-2026) — Petitioner, named in Complaint Case No. 1562 of 2023 (arising out of PS Case No. 1562 of 2023, Thana Gaya, District Gaya) for offences punishable under Sections 498A, 379, 120B of IPC and Section 3/4 of the D.P. Act, apprehended arrest. The Court noted that the allegations of mental and physical assault appeared very much general and omnibus in nature and directed release on bail 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, to the satisfaction of the learned SDJM, Gaya, subject to the conditions under Section 482(2) of BNSS. Counsel for the informant had alleged a dowry demand of Rs. 40 lakh; no precedent was cited or relied upon.

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IN THE HIGH COURT OF JUDICATURE AT PATNA CRIMINAL MISCELLANEOUS No.35507 of 2025

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Arising Out of PS. Case No.-1562 Year-2023 Thana- GAYA COMPLAINT CASE DistrictGaya

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

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Manik S/O Surendra Grover R/O 162 A, Model Town, Fatehabad, P.SFatehabad, Haryana. At present, Bank of Maharashtra, Sahakar Nagar Parvati Paitha, Pune (Maharashtra).

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... ... Petitioner/s

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Versus

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The State of Bihar

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Saloni W/O Manik R/O 162A, Model Town, Fatehbad, P.S- Fatehbad, Haryana. At present residing at Flat No. D/302, Rajvila, Gaya dobhi Road, New Airport, P.S- Magadh Medical College, Distt.- Gaya.

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... ... Opposite Party/s

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====================================================== Appearance : For the Petitioner/s : Mr. Anuj Kumar, Adv. Mr. Aditya Pandey, Adv. Ms. Eashita Raj, Adv. For the State : Mr. Md. Matloob Rab, Adv. For the Opposite Party/s: Mr. Rabia Gulnaz, Adv. Mr. Ranjana Singh, Adv. ====================================================== CORAM: HONOURABLE MR. JUSTICE CHANDRA SHEKHAR JHA

ORAL ORDER

7 21-01-2026

Heard the parties.

The petitioner is named in the complaint

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case and apprehending his arrest in connection with Complaint Case No. 1562 of 2023 registered for the offences punishable under Sections 498A, 379, 120B of IPC and Section ¾ of D.P. Act.

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The allegation against petitioner is commit mental and physical cruelty upon complainant due to non-fulfillment of demand of dowry.

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Patna High Court CR. MISC. No.35507 of 2025(7) dt.21-01-2026 2/4

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It is submitted by learned counsel

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appearing on behalf of the petitioner that even as per complaint petition it nowhere appears that the demand of dowry in actual was raised rather money was asked as a loan for purchasing flat. It is submitted that petitioner is a P.O. of bank, whereas O.P. No. 2/ complainant is a fashion designer and it was inter caste marriage and when the complainant faced inconvenience after joining her matrimonial home she left on her own.

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Arguing further, learned counsel for petitioner drawn attention of this Court towards the Court question asked to complainant while recording her S.A. during inquiry that she would not even join this petitioner as to continue her marriage life even requested by her husband/ petitioner.

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Arguing further, it is submitted that the allegation is very much general and omnibus in nature as to implicate entire family members. While concluding argument, it is submitted that petitioner is a man of clean antecedent.

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Patna High Court CR. MISC. No.35507 of 2025(7) dt.21-01-2026 3/4

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Learned APP opposes the prayer of bail.

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Mrs. Rabia Gulnaz, learned counsel for

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the informant while opposing the prayer of bail submitted that the petitioner and his family member demanded dowry of Rs. 40 lakh and due to non-fulfillment of the same committed mental and physical cruelty upon complainant.

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In view of aforesaid factual submission and by taking note of fact as allegation qua committing mental and physical assault appears very much general and omnibus in nature, accordingly petitioner above-named, in the event of his arrest or surrender before the court below within a period of four weeks, is directed to be released on bail, furnishing bail bond of Rs. 10,000/- (Rupees Ten Thousand) with two sureties of the like amount each to the satisfaction of the learned SDJM, Gaya /concerned Court, where the case is pending in connection with Complaint Case No. 1562 of 2023 , subject to the conditions as laid down under Section 482(2) of BNSS.

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Patna High Court CR. MISC. No.35507 of 2025(7) dt.21-01-2026 4/4

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(Chandra Shekhar Jha, J)

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Sudha/-

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U T

Manik v. The State of Bihar

Case brief

What is this about?

What did the court decide?

Manik v. The State of Bihar

Case brief

What is this about?

What did the court decide?

Why is it important?

What the court decided

Issues for consideration

Statutes considered

Procedural history

Parties & counsel

Coram

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