Dismissed¶21

Manish Ram @ Manish Kumar v. The State of Bihar

Bail – refusal

Patna HC25 Feb 2026CR. MISC./58613/2025

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What is this about?

Bail rejected; Bharatiya Nyaya Sanhita Sections 80(2), 238 and 3(5); Bhagwanpur P.S. Case No. 236 of 2024, Thana Bhagwanpur, District Vaishali; Manish Ram @ Manish Kumar v. The State of Bihar; Patna High Court Criminal Miscellaneous No.58613 of 2025; Satyavrat Verma, J; order dated 25-02-2026; death of wife within seven years of marriage; body cremated without postmortem; no death certificate on record; general and omnibus dowry-demand allegations; presumption of culpability of husband urged by APP; petitioner in custody since 30-4-2025; clean antecedents.

What did the court decide?

Considering the submission made by learned APP, the Court is not inclined to release the petitioner on bail. ¶21

Manish Ram @ Manish Kumar Vs The State of Bihar — Patna HC (2026) — LawSathi Research

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IN THE HIGH COURT OF JUDICATURE AT PATNA CRIMINAL MISCELLANEOUS No.58613 of 2025

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Arising Out of PS. Case No.-236 Year-2024 Thana- BHAGWANPUR District- Vaishali

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Manish Ram @ Manish Kumar S/o Satrudhan Ram @ Shatrudhan Ram Resident of Village- Asoi Sarangi, (Lacchiram), PS- Bhagwanpur, DistrictVaishali

... ... Petitioner/s

Versus

The State of Bihar

... ... Opposite Party/s

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====================================================== Appearance : For the Petitioner/s : Ms.Sudha, Adv For the Opposite Party/s : Mr. Rabindra Kumar, APP ====================================================== CORAM: HONOURABLE MR. JUSTICE SATYAVRAT VERMA ORAL ORDER

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3 25-02-2026

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1. Heard learned counsel for the petitioner and learned A.P.P. for the State.

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2. The petitioner seeks bail in connection with Bhagwanpur P.S. Case No. 236 of 2024, registered for the offences punishable under Sections 80(2), 238 and 3(5) of the Bharatiya Nyaya Sanhita.

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3. Learned counsel for the petitioner submits that petitioner is a person with clean antecedent and is in custody since 30-4-2025. It is next submitted that petitioner, being husband, has been falsely implicated in the instant case by the informant. It is further submitted that the informant alleges that her daughter was married to the petitioner and out of the wedlock, a child was born, but then her daughter was subjected

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Patna High Court CR. MISC. No.58613 of 2025(3) dt.25-02-2026 2/3

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to cruelty for non-fulfillment of dowry demand, further on 24-82024, the victim was killed and on coming to know about the occurrence, the informant along with others reached the place of occurrence, but by then the accused persons had already cremated the dead body.

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4. Learned counsel for the petitioner submits that from perusal of the allegations as alleged in the FIR, it would manifest that as far as allegation of demand of dowry and torture is alleged, the same is general and omnibus in nature. It is next submitted that the FIR does not disclose that as to what was being demanded in dowry by the accused persons including the petitioner. It is further submitted that merely because the wife died within seven years of marriage, as such a false case came to be instituted when the death was natural.

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5. Learned APP, Sri Rabindra Kumar, vehemently opposes the bail application and submits that no doubt from perusal of the allegation as alleged in the FIR, it appears that informant has not disclosed what was being demanded by way of dowry and on account of non-fulfillment of the same, the victim was tortured, but then it is submitted that what is not in dispute rather stands admitted is that victim has died. It is next submitted that whether the death was homicidal or suicidal that

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Patna High Court CR. MISC. No.58613 of 2025(3) dt.25-02-2026 3/3

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could have been ascertained had the body been sent for postmortem, but since the body was not sent for postmortem and the victim died within seven years of marriage that amply demonstrates the connivance of the petitioner being husband in the occurrence. It is also submitted that had the death been a natural death, in that event the petitioner would have ensured that the body is sent for postmortem so that the truth comes out, but in absence of postmortem, the body was cremated nor death certificate is on record. It is further submitted that even law presumes the culpability of the husband and his family members, where death occurs within seven years of marriage and the same is not substantiated by any documentary evidence to the contrary that the death was natural.

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6. Considering the submission made by learned APP,

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the Court is not inclined to release the petitioner on bail.

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7. Accordingly, the prayer for bail of the petitioner is

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rejected.

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(Satyavrat Verma, J)

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Sumit/-