Deepak Paswan @ Deepak Kumar Paswan Vs The State of Bihar — Anticipatory Bail | Patna HC (2026)

Deepak Paswan @ Deepak Kumar Paswan Vs The State of Bihar — Anticipatory Bail | Patna HC (2026)

What the court decided

AI extract

Outcome

Pre-arrest bail granted to petitioner no.1 (release upon arrest/surrender within four weeks on a Rs. 10,000/- bond with two like sureties, subject to Section 438(2) Cr.P.C / 482(2) BNSS conditions and verification of antecedents); prayer of petitioner no.2 rejected. Bail application disposed of accordingly.

Issue for consideration

Whether petitioner no.1 (Deepak Paswan @ Deepak Kumar Paswan), father-in-law of the deceased, has made out a case for release on pre-arrest bail in connection with Jandaha P.S. Case No. 278 of 2025. +1 more

Court's answer

After hearing rival submissions and perusing the F.I.R. allegations, the Court found that petitioner no.1, the father-in-law of the deceased, has made out a case for release on pre-arrest bail.

Ratio / Principle

Petitioner no.1 was directed to be released on pre-arrest bail in the event of his arrest or surrender before the Court below within four weeks, on furnishing a bail bond of Rs. 10,000/- with two sureties of the like amount each to the satisfaction of learned Additional Sessions Judge-IV, Vaishali at Hajipur, subject to the conditions under Section 438(2) Cr.P.C / 482(2) BNSS.

Key takeaways

Pre-arrest bail was refused to petitioner no.2, the mother-in-law of the deceased, because she has more influence in the family and took no action once she found her daughter-in-law missing, which led to recovery of the dead body in a jungle.ratio¶¶25
The grant of pre-arrest bail to petitioner no.1 was made conditional: the learned District Court is to verify his criminal antecedents, and if he is found involved in other cases contrary to what was stated in Para-3 of the bail petition, the order will automatically lose its force.ratio¶¶26

Detailed headnote1 paragraphs

Patna High Court (Purnendu Singh, J., oral order dated 19-03-2026) disposing of Criminal Miscellaneous No. 400 of 2026 arising out of Jandaha P.S. Case No. 278 of 2025 (Vaishali), registered under Sections 80, 238 and 3(5) of the BNS, wherein the petitioners, parents-in-law of the deceased, were alleged in the F.I.R. to have participated with co-accused in murdering the informant's daughter for non-fulfilment of dowry demand. Pre-arrest bail granted to petitioner no.1 (father-in-law), who was held to have made out a case, on a Rs. 10,000/- bond with two like sureties before Additional Sessions Judge-IV, Vaishali at Hajipur, subject to Section 438(2) Cr.P.C / 482(2) BNSS conditions, and further conditional upon District Court verification of his criminal antecedents failing which the order automatically loses force. Pre-arrest bail refused to petitioner no.2 (mother-in-law) on account of her greater influence in the family and her inaction when the daughter-in-law went missing, leading to recovery of the dead body in a jungle. Bail application stands disposed of.

IN THE HIGH COURT OF JUDICATURE AT PATNA CRIMINAL MISCELLANEOUS No.400 of 2026

Arising Out of PS. Case No.-278 Year-2025 Thana- JANDAHA District- Vaishali

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

Deepak Paswan @ Deepak Kumar Paswan S/o Kosta Paswan R/O VillageSakrauli, P.S- Mahisaur, Distt.- Vaishali.

Manju Devi @ Sanju Devi W/O Deepak Paswan @ Deepak Kumar Paswan R/O Village- Sakrauli, P.S- Mahisaur, Distt.- Vaishali.

... ... Petitioner/s

Versus

The State of Bihar

... ... Opposite Party/s

====================================================== Appearance : For the Petitioner/s : Mr.Anish Kumar, Advocate. For the Opposite Party/s : Mr.Shahabuddin Azeem @ S. Azeem, APP. ======================================================

CORAM: HONOURABLE MR. JUSTICE PURNENDU SINGH ORAL ORDER

3 19-03-2026

Heard learned counsel appearing on behalf of the

petitioners and learned APP for the State.

The petitioners seek pre-arrest bail in connection with Jandaha P.S. Case No. 278 of 2025 registered for the offence punishable under Sections 80, 238 and 3(5) of the BNS.

As per the allegation made in the F.I.R., the petitioners along with other co-accused are said to have murdered the daughter of the informant for non-fulfillment of demand of dowry.

Learned counsel appearing on behalf of the petitioners submitted that the petitioners are innocent and they have falsely been implicated in the case. The petitioners are

Patna High Court CR. MISC. No.400 of 2026(3) dt.19-03-2026 2/3

father-in-law and mother-in-law of the deceased and they are living separately and they have no concern with the affairs of their son and the daughter-in-law (deceased). They have clean antecedent.

Learned APP for the State has vehemently opposed the prayer for grant of pre-arrest bail to the petitioners.

Having heard the rival submissions made on behalf of the parties, as well as, having perused the allegation made in the F.I.R., I find that the petitioner no.1, who is the father-in-law of the deceased, has made out a case to be released on pre-arrest bail.

The petitioner no.1 is directed to be released on pre-arrest bail, in the event of his arrest or surrender before the Court below within a period of four weeks from today, on furnishing bail bond of Rs. 10,000/- (Ten thousand) with two sureties of the like amount each to the satisfaction of learned Additional Sessions Judge-IV, Vaishali at Hajipur in connection with Jandaha P.S. Case No. 278/2025, subject to the condition as laid down under Section 438(2) Cr.P.C / 482(2) BNSS.

So far as petitioner no.2 is concerned, she being the mother-in-law has more influence in the family and has not taken any action once she found that her daughter-in-law was

Patna High Court CR. MISC. No.400 of 2026(3) dt.19-03-2026 3/3

missing leading to recovery of dead body in jungle, I am not inclined to enlarger the petitioner no.2 on pre-arrest bail.

The learned District Court is directed to verify the criminal antecedent of the petitioner no.1 and if it is found that the petitioner no.1 is involved in some other cases as what has been stated in Para-3 of the bail petition, this order will automatically lose its force.

The bail application stands disposed of.

(Purnendu Singh, J)

mantreshwar/-

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