Anticipatory bail granted based on absence of dowry allegations and interim protection previously ordered.

ORDER

1. Issue notice.

2. The learned counsel for the State has accepted notice and is agreeable for final disposal of the special leave petition at the notice stage itself.

3. Leave granted. Heard learned counsel for the parties.

4. This appeal impugns order dated 24.10.2025 passed by the High Court of Punjab and Haryana at Chandigarh rejecting the anticipatory bail prayer of the appellant in connection with First Information Report (FIR) No.38/2025 registered at P.S. Ramdas, District Amritsar.

5. At the outset, the learned counsel for the appellant has pointed out that co-accused Sandeep Pal Kaur has been granted the benefit of anticipatory bail by this Court vide order dated 17.12.2025 in Criminal Appeal No.5530/2025 arising out of Special Leave Petition (Crl.) No.14522/2025.

The said order is extracted below:

“1. I.A. No. 324521/2025 is allowed.

2. Leave granted.

3. Heard learned counsel for the parties.

4. This appeal arises from an order dated 24.07.2025 passed by the High Court of Punjab and Haryana at Chandigarh rejecting the anticipatory bail prayer of the appellant in connection with FIR No. 38/2025 registered at P.S. Ramdas, District Amritsar.

5. After considering the submissions made on behalf of the petitioner, by a detailed order dated 13.10.2025, we granted interim protection. The said order is reproduced below:

“1. The contention of the learned Counsel for the petitioner is that from the allegations made in the First Information Report (“FIR”), it appears that Husband of the deceased was staying abroad (i.e. Canada) and the deceased was staying with her in-laws. The allegations are that she complained to her mother (informant) that her sister-in- law and mother-in-law create problems for her. It is the submission of the learned Counsel for the petitioner that FIR does not allege demand of dowry or harassment in connection therewith and there is no such allegation that she was ill-treated to an extent that she would be driven to commit suicide. It is thus argued that since the autopsy report reflects a case of antemortem hanging and it is not a case of dowry death, the petitioner, who is a lady, is entitled to protection, pending investigation.

2. Issue notice, returnable in six weeks.

3. Notice on behalf of the second respondent has been accepted by Mr Dinesh Verma, Advocate.

4. List the matter on 17.12.2025.

5. In the meantime, it is provided that in the event the Petitioner is arrested in connection with CRM No. 38/2025, P.S. Ramdas, District Amritsar, she shall be released on a personal bond of Rs. 25,000/- subject to an undertaking that she shall cooperate in the investigation and make herself available for interrogation as and when required by the investigating agency. She shall also submit an undertaking that she will not threaten the witnesses or tamper the evidence.”

6. On service of notice, the State as well as the Complainant is represented.

7. The learned counsel for the respondent - State submits that pursuant to the interim order, the appellant has joined investigation, though she did not provide her passport.

8. Insofar as the Complainant’s counsel is concerned, he has submitted that since the deceased committed suicide within few months of her marriage, it is not a fit case where anticipatory bail prayer of the appellant should be entertained.

9. Having regard to the nature of the relationship of the appellant with the deceased as also that she is a lady and there appear no allegations with regard to demand of dowry, we do not find a good reason to vacate the interim protection order granted on 13.10.2025, particularly when the appellant has joined the investigation.

10. Accordingly, without expressing any opinion on the merits of the prosecution case, we deem it appropriate to dispose of this appeal by making the interim order absolute subjec