Allowed¶28

Visheshwar Sahni v. The State of Bihar

Patna HC21 Jan 2026CR. MISC./68859/2025

Case brief

AI extract

What is this about?

Anticipatory bail allowed; Patna High Court; Criminal Miscellaneous No.68859 of 2025; Sourendra Pandey, J.; decided 21-01-2026; Shahpur Patori P.S. Case No. 581 of 2022, District Samastipur; dowry death; Sections 341, 323, 304(B), 201, 504, 506, 34 IPC; Sections 3/4 D.P. Act; Section 438(2) CrPC read with Section 482(2) BNSS; plea of false implication as marriage mediator; bail-bond Rs. 10,000 with two sureties; conditions incl. close-relative bailor, trial attendance, antecedent verification.

What did the court decide?

Anticipatory bail: release in the event of arrest or surrender within four weeks on bail-bond of Rs. 10,000/- with two sureties of the like amount each, subject to Section 438(2) CrPC / Section 482(2) BNSS conditions and the additional conditions enumerated in the order. ¶28

Visheshwar Sahni Vs The State of Bihar — Murder and Culpable Homicide | Patna HC (2026)

What the court decided

AI extract

Outcome

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Issue for consideration

Whether the petitioner, apprehending arrest in Shahpur Patori P.S. Case No. 581 of 2022 (offences under Sections 341, 323, 304(B), 201, 504, 506, 34 IPC and Sections 3/4 of the D.P. Act), is entitled to anticipatory bail.

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Court's answer

Anticipatory bail granted: petitioner to be released in the event of arrest or surrender before the Court below within four weeks, on furnishing bail-bond of Rs. 10,000/- with two sureties of the like amount each, subject to the conditions under Section 438(2) CrPC read with Section 482(2) BNSS and further conditions (one bailor a close relative; physical presence on every trial date; bail bond liable to cancellation on absence on two consecutive dates or violation; trial court to verify criminal antecedents without delaying acceptance of the bail bond).

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Key takeaways

Observations, if any, made in this order shall have no bearing during the trial.obiter¶27

Detailed headnote1 paragraphs

Patna High Court (Sourendra Pandey, J.), Criminal Miscellaneous No.68859 of 2025, decided 21-01-2026: Anticipatory bail granted to the petitioner, Visheshwar Sahni, apprehending arrest in Shahpur Patori P.S. Case No. 581 of 2022 (District Samastipur), registered for offences punishable under Sections 341, 323, 304(B), 201, 504, 506 and 34 IPC and Sections 3/4 of the D.P. Act, the prosecution case alleging involvement in demanding dowry leading to the death of the informant's daughter. The petitioner claimed false implication, stating he had only acted as a mediator at the time of marriage, was not an immediate family member of the deceased's husband, resided elsewhere, and had clean antecedents. Bail allowed on furnishing bail-bond of Rs. 10,000/- with two sureties of the like amount each, subject to the conditions under Section 438(2) CrPC read with Section 482(2) BNSS and further conditions: one bailor to be a close relative; physical presence before the trial court on every date; bail bond liable to cancellation on absence on two consecutive dates or violation of terms; trial court to verify criminal antecedents, without delaying acceptance of the bail bond for verification. Observations in the order to have no bearing at trial.

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IN THE HIGH COURT OF JUDICATURE AT PATNA CRIMINAL MISCELLANEOUS No.68859 of 2025

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Arising Out of PS. Case No.-581 Year-2022 Thana- SHAHPUR PATORI District- Samastipur

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

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Visheshwar Sahni S/o Late Jageshwar Sahni R/o Village- Jalalpur, P.S.Mahanar, Dist.- Vaishali

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... ... Petitioner/s

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Versus

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The State of Bihar Bihar

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... ... Opposite Party/s

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====================================================== Appearance : For the Petitioner/s : Mr.Ajay Kumar, Adv For the Opposite Party/s : Mr.Pranav Kumar, APP ======================================================

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CORAM: HONOURABLE MR. JUSTICE SOURENDRA PANDEY ORAL ORDER

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4 21-01-2026

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Heard learned counsel for the petitioner and learned

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A.P.P. for the State.

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2. The petitioner apprehends his arrest in connection with Shahpur Patori P.S. Case No. 581 of 2022 dated 08.12.2022 registered for the offences punishable under Sections 341, 323, 304(B), 201, 504, 506 and 34 of the Indian Penal Code and Sections 3/4 of the D.P. Act.

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3. As per the prosecution case, the petitioner is alleged to be a man who was involved in demanding dowry and on account of the non-fulfillment of the same, the daughter of the informant was done to death.

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4. The learned counsel for the petitioner submits that petitioner has falsely been implicated in this case merely because he had played a role of mediator at the time of

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Patna High Court CR. MISC. No.68859 of 2025(4) dt.21-01-2026 2/3

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marriage. It has further been submitted that the petitioner is not the immediate family member of the husband of the deceased and he is resident of another place. It has furhter been submitted that only to coerce the petitioner to take side of the informant, the petitioner has falsely been implicated. It has lastly been submitted that the petitioner has clean antecedent.

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5. The learned A.P.P. for the State has vehemently opposed the prayer for anticipatory bail of the petitioner.

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6. Considering the aforesaid submissions made by the parties and taking into account the facts and circumstances of the case, the petitioner, above named, is directed to be released on anticipatory bail, in the event of arrest or surrender before the Court below within a period of four weeks from today, 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 Court below where the case is pending/successor court in connection with Shahpur Patori P.S. Case No. 581 of 2022, subject to the conditions as laid down under Section 438(2) of the Code of Criminal Procedure read with corresponding Section 482(2) of BNSS as well as subject to the following conditions:-

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(i) One of the bailors will be a close relative of the

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Patna High Court CR. MISC. No.68859 of 2025(4) dt.21-01-2026 3/3

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petitioner.

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(ii) The petitioner shall remain physically present before the concerned Court on each and every date of the trial and shall cooperate in the investigation.

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(iii) In case of absence on two consecutive dates or in violation of the terms of the bail, the bail bond of the petitioner will be liable to be cancelled by the Court concerned.

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(iv) The trial court shall verify the criminal antecedent of the petitioner and in case, at any stage, it is found that the petitioner has concealed his criminal antecedents, the trial court shall take necessary steps for cancellation of bail bond of the petitioner. However, the acceptance of bail bond in terms of the above mentioned order shall not be delayed for purpose of or in the name of verification.

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7. It is made clear that the observations, if any, made in this order, shall be of no bearing during the trial.

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8. The application stands allowed.

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(Sourendra Pandey, J)

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Gautam/-

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U T

Visheshwar Sahni v. The State of Bihar

Case brief

What is this about?

What did the court decide?

Visheshwar Sahni v. The State of Bihar

Case brief

What is this about?

What did the court decide?

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What the court decided

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