SupremeToday Landscape Ad
Back
Next
Judicial Analysis Court Copy Headnote Facts Arguments Court observation
Listen Audio Icon Pause Audio Icon
judgment-img

2025 Supreme(Online)(SC) 11628

SUPREME COURT OF INDIA
SANJAY KAROL, PRASHANT KUMAR MISHRA, JJ
REENA PATEL – Appellant
Versus
STATE OF MADHYA PRADESH – Respondent
CRIMINAL APPEAL NO(s). OF 2025 | SLP (Crl.) No.9541 of 2025



Advocates:
For the Appellants/Petitioners: Mr. Sumeer Sodhi, Mr. Varun Tankha, Mr. Harshit Bari, Mr. Hardeek Goyal
For the Respondents: Mr. B.P. Singh, Mr. Sarad Kumar Singhania, Mr. Shashank Shekhar, Mr. Maditya Pratap Singh, Mr. Konark Tyagi, Mr. Jayesh Pandey, Mr. Sagar Sarda

The court affirmed the requirement for the appellant's ongoing cooperation in investigations while allowing the appeal due to procedural compliance and lack of substantial evidence against the appellant.

Headnote:(A) Criminal Procedure Code, 1973 - The appellant challenges the judgment and order passed by the High Court concerning the alleged abetment of suicide and dowry demands. The court addressed the procedural compliance during investigations and specified conditions to be followed moving forward. (Paras 1-8)

(B) Appeal Process - The court confirmed prior orders and ensured ongoing cooperation from the appellant while emphasizing the importance of adherence to legal proceedings. (Paras 7-8)

Facts of the case:
The appeal arises from a court decision concerning accusations of abetment of suicide which lacked prima facie evidence of wrongdoing regarding dowry demands.

Findings of Court:
The appellant has cooperated fully during the investigation, complying with judicial directions.

Issues: Questions surrounding the sufficiency of evidence for the allegations against the appellant formed the crux of the appellate consideration.

Ratio Decidendi: The court upheld the necessity of ongoing cooperation in criminal investigations while allowing the appeal due to procedural compliance and lack of substantive allegations supporting the original claim.

Result: The impugned judgment and order is set aside.

Table of Content
1. order granting leave and permitting service to the standing counsel. (Para 1 , 2)
2. notices compliance and cooperation of the appellant during investigation. (Para 4 , 5 , 6)
3. conditions for retaining bail and overall cooperation importance. (Para 7 , 8)
4. final decision to set aside the previous judgment. (Para 9 , 10)

O R D E R

1. Leave granted.

2. The appellant challenges the judgment and order dated 20.06.2025 in Misc. Criminal Case No.26977/2025 passed by the High Court of Madhya Pradesh Principal Seat at Jabalpur, titled “Reena Patel vs. The State of Madhya Pradesh”.

3. On 04.07.2025, this Court passed the following order:-

The contention of the learned counsel for the petitioner is that no case of abetment of suicide is made out and admittedly there is no allegation in respect of demand of dowry.

Matter requires consideration.

Issue notice to the respondents returnable within six weeks.

The learned counsel for the petitioner is permitted to serve the standing counsel representing the State of Madhya Pradesh in this court.

Signature Not Verified Digitally signed by In the meantime, if the petitioner is NAVEEN D Date: 2025.08.28

19:25:57 IST arrested in connection with FIR No.164 of Reason:

2025, he shall be released on a personal bond of Rs.25,000/- (Rupees twenty five thousand only) subject to an undertaking that he shall cooperate with the investigation and shall not threaten the witnesses or tamper with the evidence.”

4. We have heard learned counsel for the parties and also perused the materials available on record.

5. It is not in dispute that the conditions stand fully complied with; the appellant has cooperated during the investigation; she has not threatened or intimidated any of the witnesses; or has tried to influence the investigation in any manner.

6. We have noticed the nature of crime and the manner in which it was allegedly committed.

7. We allow the present appeal by confirming the order dated 04.07.2025, passed by this Court, with a direction to the appellant to continue to cooperate during the investigation/trial and not to take any unnecessary adjournment. Also, the appellant shall report before the Investigating Officer on every Monday, between 10 a.m.

and 11 a.m.

8. If the Investigating Officer/Arresting Officer/Trial Court feels that the investigation/trial is delayed on account of the appellant’s conduct, it shall be open to the Investigating Officer/Arresting Officer/Trial Court to take appropriate steps in accordance with the law, including cancellation of bail.

9. The impugned judgment and order dated 20.06.2025 is set aside.

10. Pending application(s), if any, shall stand disposed of.

..................J.

(SANJAY KAROL)

..................J.

(PRASHANT KUMAR MISHRA)

NEW DELHI

25th AUGUST 2025 ITEM NO.11 COURT NO.12 SECTION II-E S U P R E M E C O U R T O F I N D I A RECORD OF PROCEEDINGS Petition(s) for Special Leave to Appeal (Crl.) No(s).9541/2025 [Arising out of impugned final judgment and order dated 20-06-2025 in MCRC No.26977/2025 passed by the High Court of Madhya Pradesh Principal Seat at Jabalpur]

REENA PATEL PETITIONER(S)

VERSUS STATE OF MADHYA PRADESH RESPONDENT(S)

IA No. 151637/2025 - EXEMPTION FROM FILING O.T.

Date : 25-08-2025 This matter was called on for hearing today.

CORAM :

HON'BLE MR. JUSTICE SANJAY KAROL HON'BLE MR. JUSTICE PRASHANT KUMAR MISHRA For Petitioner(s) :

Mr. Sumeer Sodhi, AOR Mr. Varun Tankha, Adv. Mr. Harshit Bari, Adv.

Mr. Hardeek Goyal, Adv.

For Respondent(s) :

Mr. B.P. Singh, D.A.G.

Mr. Sarad Kumar Singhania, AOR Mr. Shashank Shekhar, Adv.

Mr. Maditya Pratap Singh, Adv.

Mr. Konark Tyagi, AOR Mr. Jayesh Pandey, Adv.

Mr. Sagar Sarda, Adv.

Upon hearing the counsel the Court made the following

O R D E R

1. Leave granted.

2. The appeal is allowed in terms of the signed order, which is placed on the file.

3. Pending application(s), if any, shall stand disposed of.

Click Here to Read the rest of this document
1
2
3
4
5
6
7
8
9
10
11
SupremeToday Portrait Ad
supreme today icon
logo-black

An indispensable Tool for Legal Professionals, Endorsed by Various High Court and Judicial Officers

Please visit our Training & Support
Center or Contact Us for assistance

qr

Scan Me!

India’s Legal research and Law Firm App, Download now!

For Daily Legal Updates, Join us on :

whatsapp-icon Back to top