1. Appeal against rejection of regular bail for offences under Sections 498A, 304B of the Indian Penal Code and Sections 3, 4 of the Dowry Prohibition Act. (Para 3 , 4 )
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2025 Supreme(SC) 1404
SUPREME COURT OF INDIA
B.V. NAGARATHNA AND SATISH CHANDRA SHARMA, JJ.
Yashasvi Jain – Appellant
Versus
State Of Madhya Pradesh – Respondent
Criminal Appeal No. 264 of 2025 (@ SLP(Criminal) No. 15330/2024)
Decided on : 17-01-2025
Important Points
The Supreme Court granted regular bail to the appellant accused under Sections 498A and 304B of the IPC and the Dowry Prohibition Act, ruling that based on the specific facts and circumstances of the case, the grounds for bail were made out.
Subject
Criminal Law - Bail
Act Referred
Headnote
(A) Indian Penal Code, 1860 - Sections 498A and 304B - Dowry Prohibition Act, 1961 - The appeal contests the High Court's order denying bail to the appellant charged with dowry-related offences following the suicide of his wife. The appellant claimed there was no dowry demand as their marriage was voluntary. The High Court rejected the bail based on the timing of the suicide relative to the marriage, thus denying merit to the bail application. (Paras 3, 8, 9)
(B) Bail - The court found the appellant's circumstances met the criteria for bail based on a lack of evidence for ongoing dowry demands, despite the widow's death occurring months after marriage. It emphasizes the importance of individual circumstances in bail decisions. (Paras 8, 9)
Facts of the case:
The appellant has been incarcerated since August 2024, following charges stemming from a report of his wife committing suicide in her parental home six months after their self-arranged marriage, with no evidence presented of a dowry demand.
Findings of Court:
The Supreme Court found sufficient grounds to grant bail, emphasizing the appellant's cooperation in the trial and the necessity of imposed conditions to prevent misuse of bail.
Issues: Whether the circumstances of the marriage and subsequent suicide justify granting bail.
Ratio Decidendi: The court concluded that the absence of dowry-related evidence, the nature of the marriage, and the elapsed time before the suicide justified granting bail despite the High Court's ruling.
Result: Appeal allowed; bail granted under specified conditions.
(B) Bail - The court found the appellant's circumstances met the criteria for bail based on a lack of evidence for ongoing dowry demands, despite the widow's death occurring months after marriage. It emphasizes the importance of individual circumstances in bail decisions. (Paras 8, 9)
Facts of the case:
The appellant has been incarcerated since August 2024, following charges stemming from a report of his wife committing suicide in her parental home six months after their self-arranged marriage, with no evidence presented of a dowry demand.
Findings of Court:
The Supreme Court found sufficient grounds to grant bail, emphasizing the appellant's cooperation in the trial and the necessity of imposed conditions to prevent misuse of bail.
Issues: Whether the circumstances of the marriage and subsequent suicide justify granting bail.
Ratio Decidendi: The court concluded that the absence of dowry-related evidence, the nature of the marriage, and the elapsed time before the suicide justified granting bail despite the High Court's ruling.
Result: Appeal allowed; bail granted under specified conditions.
Legal Category Hierarchy
Table of Contents
2. Appellant contends suicide occurred at parental home without dowry demands; State opposes bail as suicide occurred within six months of marriage. (Para 7 , 8 )
3. Upon perusing the material on record, the court found that the case for granting bail to the appellant was made out. (Para 8 )
4. Bail may be granted in matrimonial offence cases upon a judicial evaluation of the facts and circumstances available on record. (Para 8 )
5. Appeal allowed; appellant to be released on bail by the Trial Court subject to conditions ensuring presence in proceedings. (Para 9 , 10 )
6. Can bail be granted in cases involving dowry death and harassment under the Indian Penal Code?
Yes, the court may grant bail if, after considering the facts on record and the submissions of the parties, it is determined that the case for bail is made out. (Para 8 )
ORDER :
1. Leave granted.
2. This appeal challenges the judgment and order dated 25.09.2024 passed by the High Court of Madhya Pradesh at Jabalpur in Misc. Criminal Case No. 40005 of 2024.
3. The appellant has been facing trial in connection with a crime registered pursuant to First Information Report No.90 of 2024 dated 21.03.2024 lodged with Police Station Saikheda, District Narsinghpur, in respect of offences punishable under Sections 4 98A and 304B of the INDIAN PENAL CODE , 1860 and Sections 3 and 4 of the Dowry Prohibition Act, 1961.
4. An application seeking regular bail having been rejected by the High Court vide impugned order dated 25.09.2024, the appellant has preferred the instant appeal.
5. This Court, vide its order dated 11.11.2024, issued notice in the instant matter.
6. Heard learned counsel for the appellant in support of the appeal and learned counsel for the respondent-State and perused the material on record.
7. Learned senior counsel for the appellant submitted that the appellant has been in jail since August, 2024; that in fact his wife committed suicide in her parental home by hanging; that there was absolutely no demand for dowry inasmuch as the appellant and victim had married on their own accord and it was not an arranged marriage and therefore there can be no attribution of demand for dowry made on the appellant or his family. In the circumstances, this Court may set aside the impugned order and grant the relief of bail to the appellant herein.
8. Per contra, learned counsel for the respondent-State, with reference to her counter affidavit, submitted that the suicide has occurred about six months after her marriage and therefore this is not a case where the relief of bail could be granted to the appellant herein, who is none other than the husband of the victim. She therefore submitted that there is no merit in this appeal. Considering the facts on record, in our view, the case for bail is made out.
9. We, therefore, allow this appeal and direct as under:
"The appellant shall be produced before the concerned Trial Court as early as possible and the Trial Court shall release him on bail, subject to such conditions as it may deem appropriate to impose to ensure his presence in the proceedings arising out of FIR No.90 of 2024 mentioned above."
10. It is directed that the appellant shall extend complete cooperation in the trial of the instant case. The appellant shall not misuse his liberty in any manner.
Any infraction of the conditions shall entail cancellation of bail granted to the appellant.
With these observations, the appeal is allowed.
