1. Court’s Decision:
The Supreme Court canceled the bail granted to the father-in-law and mother-in-law of the deceased, holding that there was strong prima facie evidence indicating their involvement in the crime. However, the Court upheld the bail granted to the sisters-in-law, citing their lesser role and personal circumstances. The trial court was directed to expedite the proceedings, and the parents-in-law were instructed to surrender immediately, failing which they would be taken into custody.
2. Facts:
- The case originates from an FIR registered at a police station in Uttar Pradesh under Sections 498A and 304B of the Indian Penal Code (IPC), and Sections 3 and 4 of the Dowry Prohibition Act, 1961.
- The deceased was married in February 2022 and found dead in her matrimonial home in January 2024, well within the seven-year timeframe that triggers the presumption of dowry death under Section 304B IPC.
- The post-mortem examination revealed multiple ante-mortem injuries and a ligature mark around the neck, with the cause of death recorded as “asphyxia due to strangulation,” ruling out suicide.
- The deceased’s brother filed the complaint, alleging that his sister’s in-laws had been continuously demanding dowry, including a motorcycle (which was provided) and later a car (which was not provided due to financial constraints).
- The victim was allegedly subjected to continuous harassment and cruelty by her in-laws.
- The victim’s father received a phone call from the father-in-law on the day of the incident, asking him to come immediately. Upon arrival, they found the deceased hanging from a ceiling fan, with her knees still resting on the bed—raising serious doubts about whether it was a case of suicide.
- The Sessions Court denied bail to the accused, citing strong evidence of dowry-related harassment and unnatural death.
- The High Court granted bail to the accused, reasoning that they had no prior criminal records and that some of them were women.
3. Issues:
- Did the High Court err in granting bail to the accused despite the seriousness of the allegations?
- Was there sufficient evidence to establish the involvement of the accused in the dowry-related harassment and death?
- What approach should courts take in granting bail in dowry death cases?
4. Petitioner’s Arguments:
- The prosecution argued that the High Court failed to properly assess the gravity of the allegations while granting bail.
- Medical evidence suggested forced strangulation, making the High Court’s decision to grant bail questionable.
- The in-laws continued to demand dowry even after receiving a motorcycle and became aggressive when their demand for a car was denied.
- The deceased was subjected to physical violence, and the post-mortem revealed multiple injuries inconsistent with suicide.
- The trial court had correctly denied bail because of strong material evidence against the accused.
5. Respondent’s Arguments:
- The accused had no prior criminal record, which justified bail.
- The sisters-in-law had minimal involvement, and one of them was recently married, while the other was still studying.
- The father-in-law calling the deceased’s family suggested that they were not involved in the crime.
- The High Court had considered relevant factors, such as the accused being women and the fact that some co-accused had already been granted bail.
6. Analysis of the Law:
The case involves two major legal provisions:
- Section 304B IPC (Dowry Death) presumes that if a woman dies an unnatural death within seven years of marriage, and there is evidence of dowry-related harassment, the husband or in-laws are presumed guilty unless they prove otherwise.
- Section 498A IPC penalizes cruelty by a husband or in-laws.
- Sections 3 and 4 of the Dowry Prohibition Act criminalize the act of demanding or giving dowry.
- The Supreme Court has emphasized in previous rulings that in cases involving the unnatural death of a woman due to dowry harassment, courts must adopt a stricter approach while granting bail.
7. Precedent Analysis:
The Supreme Court cited Ajwar v. Waseem (2024) 10 SCC 768, which highlighted key factors to consider when granting bail in serious criminal cases:
- The nature and gravity of the allegations.
- The role attributed to the accused in the crime.
- The likelihood of tampering with evidence.
- The impact on society if bail is granted.
- Whether the trial can proceed fairly if the accused remain free.
The Court reaffirmed that bail should be canceled if:
- The lower court ignored relevant material while granting bail.
- The gravity of the offence was not adequately considered.
- The order was mechanical or perverse.
8. Court’s Reasoning:
- The father-in-law and mother-in-law played a key role in the dowry demands and harassment.
- The post-mortem findings contradicted the suicide claim, strengthening the case for dowry-related murder.
- The High Court had failed to give due weight to these factors while granting bail.
- The sisters-in-law, though implicated, had a relatively minor role, and their bail was upheld due to their personal and educational circumstances.
- The Court emphasized the importance of sending a strong societal message against dowry deaths and ensuring judicial scrutiny in such cases.
9. Conclusion:
- Bail for the father-in-law and mother-in-law was canceled due to substantial evidence of their involvement.
- The sisters-in-law were allowed to remain on bail, though they were not absolved of charges.
- The trial court was instructed to expedite proceedings, ensuring a fair trial without undue delays.
- The Supreme Court reinforced the need for stricter scrutiny in dowry death cases, ensuring justice for victims and preventing the normalization of such crimes.
10. Implications:
- The ruling sets a precedent for lower courts to be more cautious in granting bail in dowry death cases.
- It reinforces that bail should not be granted mechanically without assessing the gravity of the allegations.
- It deters dowry-related harassment by making it clear that the courts will adopt a strict approach in such cases.
- The decision safeguards public faith in the judiciary, emphasizing that justice must be seen as well as done.