Md. Wahid Vs The State of Bihar — Dowry and Cruelty | Patna HC (2026)

Md. Wahid Vs The State of Bihar — Dowry and Cruelty | Patna HC (2026)

What the court decided

AI extract

Outcome

Anticipatory bail granted: petitioner, in the event of arrest or surrender within four weeks, to be enlarged on bail on furnishing bail bond of Rs.10,000/- with two sureties of the like amount each to the satisfaction of the learned C.J.M., Araria, in connection with Complaint Case No.1936 of 2024, subject to conditions under section 482(2) of the Bharatiya Nagarik Suraksha Sanhita, 2023; parties directed to adhere to the mediation settlement terms and the court below directed to dispose of the case in terms of the settlement.

Issue for consideration

Whether the petitioner, apprehending arrest in Complaint Case No.1936 of 2024 registered for an offence punishable under Section 85/3(5) of the BNS, 2023, should be granted anticipatory bail.

Court's answer

Considering the one-time settlement arrived at between the parties, as apparent from the Mediation report dated 18.12.2025, the petitioner is granted the privilege of anticipatory bail, and the parties are directed to adhere to the terms and conditions of the settlement.

Ratio / Principle

The parties are at liberty to bring the one-time settlement arrived at during mediation before the learned Court below, which is directed to pass appropriate orders in accordance with law for disposing of the case in terms of the settlement.

Key takeaways

In the event of arrest or surrender within four weeks, the petitioner is to be enlarged 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 C.J.M., Araria, in connection with Complaint Case No.1936 of 2024, subject to the conditions laid down under section 482(2) of the Bharatiya Nagarik Suraksha Sanhita, 2023.ratio¶25

Detailed headnote1 paragraphs

Anticipatory bail — Patna High Court grants anticipatory bail to the petitioner in Complaint Case No.1936 of 2024 (offence punishable under Section 85/3(5), BNS, 2023, District Araria), in which the complainant, the petitioner's wife, alleged that after Bidai the accused persons demanded two lakh cash and a buffalo and ousted her from the matrimonial house, and a Panchayati on 25.09.2024 failed. A one-time settlement was arrived at between the parties in mediation (mediator's report dated 18.12.2025); considering the settlement, the petitioner, if arrested or surrendering within four weeks, is to be enlarged on bail on furnishing bail bond of Rs.10,000/- with two sureties of the like amount each to the satisfaction of the learned C.J.M., Araria, subject to the conditions under section 482(2) of the Bharatiya Nagarik Suraksha Sanhita, 2023. Parties directed to adhere to the settlement terms; court below directed to dispose of the case in terms of the settlement.

IN THE HIGH COURT OF JUDICATURE AT PATNA CRIMINAL MISCELLANEOUS No.64688 of 2025

Arising Out of PS. Case No.-1936 Year-2024 Thana- COMPLAINT CASE District- Araria

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Md. Wahid S/o- Late Md. Mustafa Village - Sukhasarni Balwan ward no- 9, Ps- Palasi Dist- Arariya

... ... Petitioner/s

Versus

The State of Bihar

Asrana D/o- Baharuddin, W/o- Md. Wahid Village- Joginder Bhansiya W.No-10, Po- Gairaki Ps- Mahalgaon Dist- Arariya

... ... Opposite Party/s

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Appearance :

For the Petitioner/s : Mr.Pratibha Srivastava, Advocate For the Opposite Party/s : Mr.Mritunjay Kumar Nirala, APP ======================================================

CORAM: HONOURABLE MR. JUSTICE ALOK KUMAR SINHA ORAL ORDER

4 17-01-2026

Heard learned counsel for the petitioner and learned

A.P.P. for the State.

Petitioner apprehends his arrest in a case registered for the offence punishable under Section 85/3(5) of the BNS, 2023.

Prosecution story in brief is that complaint case No.1936 C/2024 was filed by Opposite Party No.2 on 28.9.2024 in the Court of C.J.M.,Araria against the petitioner and others alleging there is that she was married with petitioner on 29.07.2024 in accordance with Muslim law and customs. At the time of marriage, several articles were givne to in-laws in gift., It is further alleged that after Bidai, the accused persons

Patna High Court CR. MISC. No.64688 of 2025(4) dt.17-01-2026 2/3

demanded two lakh cash and a Buffalo and finally ousted her from the matrimonial house. On 25.09.2024 a Panchayati was held but the accused persons were not ready to keep the complainant without Rs.2 lakh and a buffalo. Hence the present case.

Learned counsel for the petitioner submits that the petitioner is innocent and has falsely been implicated in the present case. He further submits that matter has been settled in Mediation and learned Mediatior has submitted his report dated 18.12.2025. The petitioner has no criminal antecedent, as statement made in para 3 of the bail application.

Learned A.P.P. for the State opposes the prayer for anticipatory bail of the petitioner.

Considering the fact that one time settlement has arrived at between the parties as is apparent from the Mediation report dated 18.12.2025, the petitioner is granted privilege of anticipatory bail and the parties are directed to adhere to the terms and conditions of the one time settlement. The parties are at liberty to bring the one time settlement which has been arrived at during Mediation before the learned Court below and learned Court below is directed to pass appropriate order in the case in accordance with law for disposing the case in terms of the settlement.

Patna High Court CR. MISC. No.64688 of 2025(4) dt.17-01-2026 3/3

Let the petitioner, as named above, in the event of his arrest or surrender within four weeks from today, be enlarged 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 C.J.M., Araria, in connection with Complaint Case No.1936 of 2024, subject to the conditions laid down under section 482(2) of the Bharatiya Nagarik Suraksha

Sanhita, 2023.

(Alok Kumar Sinha, J)

sanjeev/-

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