Abhijit Pandey vs State of Madhya Pradesh

Judicial Analysis Court Copy Headnote Facts Arguments Court observation

2026 Supreme(SC) 90

PRASHANT KUMAR MISHRA, N. V. ANJARIA
Abhijit Pandey – Appellant
Versus
State of Madhya Pradesh – Respondent

Advocates appeared:
For the Petitioner(s): Mr. Vivek K Tankha, Sr. Adv. Mr. Aditya Dev Triguna, Adv. Mr. Dhawesh Pahuja, AOR Mr. Vipul Tiwari, Adv. Mr. Inder Dev, Adv. Mr. Chaitanya Sharma, Adv.
For the Respondent(s):Mr. Sridhar Potaraju, A.A.G. Mr. D. S. Parmar, A.A.G. Ms. Mrinal Gopal Elker, AOR Mr. Abhimanyu Singh, Government Advocate Mr. Saurabh Singh, Adv. Mr. Chinmoy Chaitanya, Adv. Mr. Aditya Chaudhary, Adv. Ms. Silpi S. Swain, Adv. Mr. Praveen Chaturvedi, AOR Mr. Shashindra Tripathi, Adv.

Judgement Key Points

The judgment primarily concerns the grant of bail to the appellant in a case involving the death of the deceased, who was initially suspected to have committed suicide. The Court examined whether the appellant, accused of offences including abetment to suicide and other charges under relevant laws, should be released on bail. It was noted that the appellant, a practicing dentist, was not considered a hardened criminal and had been in custody since March 2025, with the charge-sheet filed subsequently. The Court observed that the deceased’s death was found to be caused by an anesthetic agent, which she was qualified to administer as an anesthetist, and that there was no immediate evidence of physical assault or demand for dowry in the initial case diary statements. The Court also highlighted that the allegations of demand for dowry or money emerged later and that the evidence did not conclusively establish the appellant’s involvement in abetment or murder. Based on these considerations, the Court allowed the appeal, set aside the order of the High Court rejecting bail, and directed the appellant’s release on bail with appropriate conditions. The Court clarified that the observations made were solely for the purpose of deciding the bail application and should not influence the main trial, which must be conducted independently and on its merits.

JUDGMENT

PRASHANT KUMAR MISHRA, J.

1. Leave granted.

2. In the instant Appeal, the appellant is challenging the order dated 06.10.2025 passed by the High Court of Madhya Pradesh in Misc. Criminal Case No.22396 of 2025 whereby the High Court has rejected his regular bail application filed under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023 in connection with FIR/Crime No.105/2025 registered at Police Station – Shahpura, District – Bhopal, Madhya Pradesh, for the offence punishable under Section 108 of the Bharatiya Nyaya Sanhita, 2023 (for short, ‘the BNS’). However, subsequently, a charge-sheet has been filed for the offences punishable under Sections 108 and 80 of the BNS and Sections 3 and 4 of the Dowry Prohibition Act.

3. The appellant, a dentist, was running a clinic at M.P. Nagar, Bhopal, Madhya Pradesh, where he came in contact with the deceased-Dr. Richa Pandey. After one and a half years of relationship, they got married on 04.12.2024 and started their matrimonial life while residing at House No.16, Sky Dream Colony, Bhopal. The deceased died on 21.03.2025 which was initially termed as suicide, but subsequently, a charge-sheet was filed for the offences punishabl

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