Judiciary To Reflect Heightened Vigilance When Young Bride Dies Under Suspicious Circumstances Within 2 Years Of Marriage: Supreme Court Cancels Bail Granted To Parents-in-Law

The Apex Court was considering four criminal appeals preferred against four separate orders of the Allahabad High Court granting bail to the respondents (in-laws of the deceased woman).

Expressing concern over the seemingly mechanical approach adopted by the High Court in granting bail to the respondents accused, the Division Bench comprisisng Justice Vikram Nath and Justice Sandeep Mehta asserted, “The social message emanating from judicial orders in such cases cannot be overstated: when a young bride dies under suspicious circumstances within barely two years of marriage, the judiciary must reflect heightened vigilance and seriousness. A superficial application of bail parameters not only undermines the gravity of the offence itself but also risks weakening public faith in the judiciary’s resolve to combat the menace of dowry deaths.

Advocate S. M. Tripathi represented the Appellant while AOR Rohit K. Singh represented the Respondent.

Factual Background

The appellant’s case arose from an FIR registered under Sections 498A and 304B of the Indian Penal Code, along with Sections 3 and 4 of the Dowry Prohibition Act, 1961. The FIR was lodged by the appellant (the brother of the deceased woman), stating that his sister got married in the year 2022 to the first accused (husband of the deceased). Shortly after the marriage, the family members of her matrimonial home, i.e. the other accused persons- father-in-law, mother-in-law and sisters-in-law began demanding additional dowry. As these dowry demands were not completely met due to financial constraints, the deceased was subjected to continuous harassment and cruelty by the accused in-laws as well as by her husband, who resided abroad at the relevant time.

One day, the appellant’s father received a phone call from the accused father-in-law asking him to come immediately. When the Appellant, his father, mother, and other relatives reached the matrimonial home, they allegedly found the deceased’s body with a dupatta around her neck, tied to the ceiling fan, and her knees still resting on the bed. A criminal case was registered against the accused persons, and the Sessions Judge rejected the bail applications filed by the accused respondents. However, the Allahabad High Court allowed the bail plea of the accused respondents, primarily citing factors such as the accused having no prior criminal history and some of them being women. Aggrieved thereby, the appellant approached the Apex Court.

Reasoning

The Bench found that the deceased had married the first accused in 2022 and had died under highly suspicious circumstances in the year 2024, well within the seven-year window that invokes Section 304B of IPC. Her body was bearing multiple ante-mortem injuries and a pronounced ligature mark signifying strangulation. The post-mortem details revealed traumatic contusions on the head and neck, indicating severe physical violence before her demise.

“When such brutality is combined with a clear pattern of dowry demands, including a “Bullet” motorcycle initially and later a car, the possibility of a dowry-related killing becomes alarmingly evident. Stricter judicial scrutiny is necessary in matters where a young woman loses her life in her matrimonial home so soon after marriage, particularly where the record points to persistent harassment over unmet dowry demands”, the Bench said.

The material on record also showed that the second accused (father-in-law) and the third accused (mother-in-law) had a principal role in pressuring the deceased with repeated demands for expensive items and subjecting her to relentless cruelty. Moreover, the deceased’s final moments appeared to have involved intense violence, evidenced by multiple contusions and injuries that are inconsistent with a mere case of suicide. As per the Bench, the father-in-law’s subsequent phone call to the deceased’s parental home, urging them to rush over, when considered alongside the forensic and testimonial evidence, casts further doubt on the entire chain of events leading to the victim’s death.

“In dowry-death cases, courts must be mindful of the broader societal impact, given that the offence strikes at the very root of social justice and equality. Allowing alleged prime perpetrators of such heinous acts to remain on bail, where the evidence indicates they actively inflicted physical, as well as mental, torment, could undermine not only the fairness of the trial but also public confidence in the criminal justice system”, the Bench held.

The Court was of the view that the gravity of the allegations, ranging from demands for costly gifts to the infliction of brutal injuries, demonstrated a strong prima facie case against them. “Moreover, Section 304B IPC (dowry death) prescribes a stringent standard because of the grave nature of the offence and the systemic harm it perpetuates. Where the facts clearly indicate direct involvement in the fatal events, courts must act with an abundance of caution”, it added. The Bench thus held that the bail of the accused father-in-law and mother-in-law warranted cancellation.

However, the Bench found that the role of the sisters-in-law of the deceased appeared relatively less direct. “ Although we do not exonerate them from the allegations at this stage, we find it appropriate to extend a measure of leniency towards them by not interfering with the bail granted. This consideration stems solely from their personal and educational circumstances and should not be construed as a reflection on the merits of the allegations against them”, it said.

Thus, the Bench cancelled the bail granted to the second accused (father-in-law) and third accused (mother-in-law) while upholding the bail granted to the sisters-in-law.

Cause Title: X v. The State of Uttar Pradesh & Anr. (Neutral Citation:2025 INSC 307)

Appearance:

Appellant: Advocate S. M. Tripathi, AOR Rusheet Saluja

Respondent: AOR Rohit K. Singh, AOR Rashmi Singhania, Advocates Shalini Sharma, Yash Singhania, Adv.

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