Dismissed¶21

Laldeo Mahto v. The State of Bihar

Patna HC11 Feb 2026CR. MISC./80356/2025

Case brief

AI extract

What is this about?

Patna High Court bail rejection; Criminal Miscellaneous No. 80356 of 2025; Justice Rudra Prakash Mishra; order dated 11-02-2026; Dariyapur P.S. Case No. 449 of 2025, District Saran; Sections 80 and 3(5), Bharatiya Nyaya Sanhita, 2023; alleged dowry-related killing of wife by husband and in-laws; petitioner-husband; charge-sheet submitted; custody since 14.07.2025; no criminal antecedent; general and omnibus allegation contention; gravity of offence; trial to be expedited; four-month deadline; liberty to renew bail prayer in Court below; counsel Prabhat Kumar Singh; APP Amitesh Kumar.

What did the court decide?

Bail refused; however, the petitioner may renew his prayer for bail in the Court below if the trial is not concluded within four months from the date of receipt/production. ¶21

Laldeo Mahto Vs The State of Bihar — Patna HC (2026) — LawSathi Research

What the court decided

AI extract

Outcome

Bail refused; however, the petitioner may renew his prayer for bail in the Court below if the trial is not concluded within four months from the date of receipt/production.

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Issue for consideration

Whether the petitioner, arraigned in Dariyapur P.S. Case No. 449 of 2025 (Sections 80 and 3(5), Bharatiya Nyaya Sanhita, 2023) for the alleged killing of his wife over a dowry demand, should be granted bail.

¶14

Court's answer

Considering the facts and circumstances of the case, the nature of accusation and the gravity of the offence, the Court was not inclined to grant bail to the petitioner.

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Ratio / Principle

The prayer for bail is rejected and the trial Court is directed to expedite the trial.

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Key takeaways

If the trial is not concluded within four months from the date of receipt/production, the petitioner will have liberty to renew his prayer for bail in the Court below.ratio¶23

Detailed headnote1 paragraphs

Bail refused — High Court of Judicature at Patna (Rudra Prakash Mishra, J.), Criminal Miscellaneous No. 80356 of 2025, order dated 11-02-2026. Laldeo Mahto, husband of the deceased, sought bail in Dariyapur P.S. Case No. 449 of 2025 (District Saran), instituted for offences punishable under Sections 80 and 3(5) of the Bharatiya Nyaya Sanhita, 2023. Prosecution case: the informant's daughter was allegedly done to death by her husband and in-laws for non-fulfilment of a dowry demand. Charge-sheet had been submitted; petitioner in custody since 14.07.2025 with no criminal antecedent; defence contended the allegations were general and omnibus, while the APP pointed to supporting witnesses in paragraphs 3 and 4 of the case diary. Weighing the nature of accusation and the gravity of the offence, the Court rejected the prayer, directed the trial Court to expedite the trial, and permitted the petitioner to renew his bail prayer before the Court below if the trial is not concluded within four months from the date of receipt/production.

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IN THE HIGH COURT OF JUDICATURE AT PATNA CRIMINAL MISCELLANEOUS No.80356 of 2025

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Arising Out of PS. Case No.-449 Year-2025 Thana- DARIYAPUR District- Saran

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

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Laldeo Mahto Son of Krishna Mahto Resident Of Village -Tarwan Mangarpal, Ps -Dariyapur, Dist- Saran

... ... Petitioner/s

Versus

The State of Bihar

... ... Opposite Party/s

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====================================================== Appearance : For the Petitioner/s : Mr. Prabhat Kumar Singh, Advocate For the Opposite Party/s : Mr. Amitesh Kumar, APP ======================================================

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CORAM: HONOURABLE MR. JUSTICE RUDRA PRAKASH MISHRA

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ORAL ORDER

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3 11-02-2026

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Heard learned counsel for the petitioner, learned APP for the State and perused the case diary.

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The petitioner seeks bail in connection with Dariyapur P.S. Case No. 449 of 2025, instituted for the offences punishable under Sections 80 and 3(5) of the Bharatiya Nyaya Sanhita, 2023.

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The prosecution case, in short, is that daughter of the informant has been done to death by her husband and inlaws for non-fulfillment of demand of dowry.

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Learned counsel for the petitioner submits that the petitioner is innocent and has falsely been implicated in the present case. Charge-sheet has been submitted in this case. Learned counsel for the petitioner also submitted that the

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Patna High Court CR. MISC. No.80356 of 2025(3) dt.11-02-2026 2/3

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petitioner is husband of the deceased and their marriage was solemnized nine years ago. It is next submitted that the petitioner has never made any demand of dowry from the deceased. The allegation levelled against the petitioner is not specific rather the same is general and omnibus in nature. It is further submitted that the petitioner as being husband of the deceased has been falsely implicated in this case. The petitioner is in custody since 14.07.2025 and has got no criminal antecedent.

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Learned APP for the State has vehemently opposed the prayer for grant of bail to the petitioner and submitted that there is specific allegation levelled against the petitioner. It is further submitted that in paragraph nos. 3 and 4 of the case diary, it transpires that the witnesses have supported the prosecution case. Hence, the petitioner does not deserve the privilege of bail.

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Considering the aforesaid facts and circumstances of the case, nature of accusation and the gravity of the offence, this Court is not inclined to grant bail to the petitioner.

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The prayer is rejected. The trial Court is directed to expedite the Trial. However, if the trial is not concluded within a period of four months from the date of receipt/production, the

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Patna High Court CR. MISC. No.80356 of 2025(3) dt.11-02-2026 3/3

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petitioner will have liberty to renew his prayer for bail in the Court below.

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(Rudra Prakash Mishra, J)

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Rajorshi/-

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U T

Laldeo Mahto v. The State of Bihar

Case brief

What is this about?

What did the court decide?

Laldeo Mahto 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

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