The Delhi High Court has refused anticipatory bail to a husband, father-in-law, and mother-in-law accused in a dowry death case involving the death of a 25-year-old woman within seven months of her marriage. At a time when the Supreme Court has taken suo motu cognizance of the alleged shocking death of 33-year-old corporate professional Twisha Sharma, the Delhi High Court lamented that it was 'yet another case of a young girl losing her life within six months of marriage'.

The Court noted that while the deceased died on July 02, 2025, the FIR was registered more than eight months later on 13 March 2026, and only after a Magistrate's intervention. Observing that the FIR took longer to register than the marriage lasted, it held that the accused could not benefit from a delay attributable to the investigating agency rather than the complainant.

The Court also made poignant observations about the expectations placed upon bereaved parents in dowry death cases. Asking, “Should the bereaved parents of a married daughter who dies an unnatural death within a few months of marriage be denied even the time to grieve?”, the Court held that the law cannot expect a father standing beside his daughter’s body to immediately narrate every allegation of cruelty and dowry harassment with precision. It emphasized that a grieving parent cannot be expected to display the composure of a trained investigator in the immediate aftermath of such a devastating loss.

Justice Swarana Kanta Sharma categorically observed, “The present case brings forth the story of a grieving father who, on the very day of losing his young daughter, was expected to recount before the Executive Magistrate, every instance, of alleged cruelty, every demand for dowry, every humiliation suffered by his daughter in her matrimonial home, and every circumstance which, according to him, had led to her untimely death”.

“…The allegations are neither vague nor omnibus in nature. Various specific instances have been mentioned and incidents narrated in the complaint which, according to the complainant, were disclosed by the deceased during her matrimonial life. At this stage, when the accused persons have not joined investigation and NBWs stand issued against them, the allegations cannot be brushed aside as inherently improbable”, further noted.

Advocate Prashant Sharma appeared for the petitioner and Naresh Kumar Chahar, APP appeared for the respondent.

“…this Court is shocked that despite the crime scene having been inspected on the day the unfortunate incident of deceased having died, broken bangles and pieces of anklets of the deceased were found scattered on the floor. Despite this, it is shocking that the Police did not even then, deem it appropriate to conclude that the case needed probe and registration of the FIR…”.

For background, the deceased, had married Sandeep on December 11, 2024 and died on July 03, 2025 after being admitted to hospital in critical condition. While the husband initially informed her parents that she had fallen from a staircase, hospital records later reflected a history of hanging. The deceased succumbed during treatment.

A key argument advanced by the accused was that the FIR had been registered nearly nine months after the incident and that the deceased’s parents had not made detailed allegations of dowry harassment in their statements before the Executive Magistrate immediately after her death. The Court, however, rejected this contention.

Addressing the issue of delayed and incomplete initial statements, the Court remarked that a grieving parent cannot reasonably be expected to recount every incident of harassment and dowry demand while coping with the sudden death of a young daughter.

“The present case brings forth the story of a grieving father who, on the very day of losing his young daughter, was expected to recount before the Executive Magistrate, every instance, of alleged cruelty, every demand for dowry, every humiliation suffered by his daughter in her matrimonial home, and every circumstance which, according to him, had led to her untimely death…A father who had just witnessed the death of his young daughter, whose body was still lying in the mortuary, and whom he had married off only a few months earlier, cannot reasonably be expected to narrate, with precision and completeness, the entire history of her matrimonial life while still reeling under the shock of her loss. The law cannot demand from a bereaved parent, in the immediate aftermath of such a tragedy, the composure of a trained investigator or the recollection of a meticulously prepared complainant”, the Bench said.

“Another aspect which cannot be ignored while deciding the present bail application is the fact that a helpless father was unable to get even the FIR registered regarding the death of his daughter within almost six months of the marriage. The system took almost nine months to register an FIR, resulting in plea by the applicants to grant bail due to such delay. However, the cry for justice and the obligation of law to do justice cannot be sacrificed at the altar of the delay caused by the investigating system”, further said.

The Court noted that both parents had, on the very day of their daughter's death, expressed suspicion against her husband and in-laws before the Executive Magistrate and sought justice. The Executive Magistrate had accordingly directed the SHO to conduct an inquiry and take action as per law.

Subsequently, within about two weeks of the death, the father submitted a detailed complaint alleging persistent dowry demands, physical and mental cruelty, demands for cash, an air-conditioner, a heavier gold chain, and ₹3.5 lakh for construction of a separate floor. He also alleged that the deceased had been forced to sign divorce papers and was assaulted and threatened by her husband.

The Court held that this later complaint could not be treated as an afterthought merely because the parents had not narrated every detail in their first statements recorded shortly after the death.

Significantly, the Court found fault with the investigating agency for failing to register an FIR despite the parents’ suspicions and the detailed complaint. The FIR was ultimately registered only on 13 March 2026 after judicial intervention under Section 175(4) BNSS.

The Court further noted that the investigation remained at a nascent stage and that the accused had not joined the investigation despite non-bailable warrants having been issued against them. It therefore held that custodial interrogation could not be ruled out.

“Though arguments are raised and questions are asked frequently regarding the misuse of law, this is one such case where the Court has to rather question as to why machinery of law was not used and set into motion, where it was so required. The evidence once lost in such cases where an innocent life already stood lost, is difficult to compensate by even orders as the present one and words of sympathy by the system”, the Bench further observed.

Cause Title: Sandeep @ Sunny v. The State Of NCT Of Delhi (Neutral Citation: 2026:DHC:5004)

Appearances:

Petitioners: Prashant Sharma, Sarthak Gupta, Atti Tyagi, Rohit Gupta, Advocates.

Respondents: Naresh Kumar Chahar, APP.

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