Summary
| Category | Data |
|---|---|
| Court | Supreme Court of India |
| Case Number | Crl.A. No.-000446-000446 – 2026 |
| Diary Number | 59871/2025 |
| Judge Name | HON’BLE MR. JUSTICE PRASHANT KUMAR MISHRA |
| Bench |
|
| Precedent Value | Binding |
| Overrules / Affirms | Affirms |
| Type of Law | Criminal Bail Jurisprudence under the Bharatiya Nagarik Suraksha Sanhita, 2023 |
| Questions of Law |
|
| Ratio Decidendi |
The Court held that bail must be granted if there is no prima facie material to support charges, especially when initial FIR alleges only abetment to suicide and later allegations of dowry demand arise by way of improvement. Injuries noted in the post-mortem could be self-inflicted or unrelated to the cause of death. The appellant was not a hardened criminal, had been in custody since March 2025, and there was no risk of absconding. Applying the liberal discretionary power under Section 483 BNS, bail was granted. |
| Logic / Jurisprudence / Authorities Relied Upon by the Court |
The Court examined the FIR, first statements, post-mortem injury analysis (Query Report), and the charge-sheet to determine that the prima facie case was weak. It applied the discretionary bail principles under Section 483 BNS, considering the nature of injuries, improvement in allegations, the appellant’s profile, and custody period. |
| Facts as Summarised by the Court |
The appellant, a dentist, married the deceased; she was found dead on 21.03.2025, initially treated as suicide. FIR registered under abetment to suicide. Charge-sheet framed under Sections 108 and 80(2) BNS and Dowry Prohibition Act after subsequent statements introduced dowry allegations. Post-mortem recorded needle-prick marks and other injuries. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts |
What’s New / What Lawyers Should Note
- Supreme Court confirms that bail under Section 483 BNS can be granted when prima facie evidence is weak or insufficient.
- Improvement of allegations (e.g., dowry demand introduced only in subsequent statements) cannot justify denial of bail.
- Injuries that could be self-inflicted or unrelated to death should be carefully examined before refusing bail.
- The non-hardened criminal status and prolonged pre-trial custody weigh strongly in favour of bail.
- Courts must prioritize initial case record and material over later embellishments when exercising bail discretion.
Summary of Legal Reasoning
- Initial FIR vs Subsequent Allegations
The FIR alleged only abetment to suicide due to marital discord; no dowry demand was mentioned initially. - Post-Mortem Injuries Analysis
Injuries were mostly needle pricks or abrasions; the Query Report indicated these could be self-inflicted or incidental. - Prima Facie Case Assessment
There was insufficient material to prima facie conclude murder or dowry death; only a weak case of abetment to suicide remained. - Discretion under Section 483 BNS
Applying the inherent discretionary power, the Court held that bail must be granted when the case is not made out prima facie. - Custody Duration and Appellant Profile
The appellant had been in custody since March 2025 and was not a hardened criminal, reducing the risk of absconding or tampering with evidence.
Arguments by the Parties
Petitioner
- The death was a suicide caused by emotional distress over a suspected extra-marital affair.
- No material in FIR or first statements supports dowry demand or abetment to suicide.
- Appellant is a professional, not a hardened criminal, and ready to comply with bail conditions.
Respondent (State & Complainant)
- Alleged murder by injecting Atracurium Besylate; post-mortem noted ante-mortem injuries.
- Witness statements (mother, father, brother, uncle) later included dowry demand.
- Seriousness of offences (dowry death, abetment) justifies custodial trial and denial of bail.
Factual Background
The appellant, a dentist in Bhopal, married the deceased in December 2024. On 21.03.2025 she was found dead in their home; police treated it initially as suicide. An FIR for abetment to suicide was registered on 24.03.2025. Subsequent statements led to charges under Sections 108 and 80(2) BNS and the Dowry Prohibition Act. The post-mortem, conducted on 22.03.2025, recorded needle-prick marks, abrasions, contusions and a subscalp hematoma. The appellant has been in custody since 25.03.2025.
Statutory Analysis
- Section 483 BNS (Bharatiya Nagarik Suraksha Sanhita, 2023)
Grants inherent power to high courts and courts of session to bail an accused when no prima facie case is made out. - Section 108 & 80(2) BNS
Pertains to abetment to suicide; alternate framing under Sections 103 & 85 BNS for dowry death. - Sections 3 & 4 Dowry Prohibition Act
Criminalises demand, repayment, and giving of dowry. - Interpretation
Bail discretion must focus on the strength of material on record, primary allegations, and likelihood of influencing witnesses.
Alert Indicators
- ✔ Precedent Followed – Existing bail jurisprudence under Section 483 BNS affirmed.