Nillum Batra vs State & Ors

* IN THE HIGH COURT OF DELHI AT NEW DELHI
Reserved on: 27.10.2026
Date of Decision: 04.11.2026
Uploaded on: 04.11.2026
# CNR No. DLHC010086612020
+ CRL.REV.P. 29/2020 & CRL.M.A. 704/2020
NILLUM BATRA .....Petitioner
Through: Mr. Vishal Gosain, Sr Adv with Ms.
Anushka Baruah and Mr. Pranav Das,
Advs.
Ms. Rebecca M. John, Sr. Adv. with
Mr. Pravir Singh and Ms. Anushka
Baruah, Advs.
versus
STATE & ORS .....Respondents
Through: Ms. Meenakshi Dahiya, APP
Mr. Siddharth Aggarwal, Sr. Adv. and
Mr. Amit Chadha, Sr. Adv., along with
Mr. Pankaj Baghla, Ms. Vismita
Diwam, Mr. Gurpreet Singh, Mr.
Siddhant Saraswat, Mr. Manjit Walia
and Mr. Harjas Singh, Advs. for R2 to
R4.
Insp. Sanjay Kaushik, NR-1, Crime
Branch.
# CNR No. DLHC010153802021
+ CRL.REV.P. 170/2021 & CRL.M.A. 5849/2021
MAYANK SINGHVI .....Petitioner
Through: Mr. Siddharth Aggarwal, Sr. Adv.
and Mr. Amit Chadha, Sr. Adv., Mr.
Pankaj Baghla, Ms. Vismita Diwam,
Mr. Gurpreet Singh, Mr. Siddhant
Saraswat, Mr. Manjit Walia and Mr.
Harjas Singh, Advs
versus
STATE (NCT) OF DELHI .....Respondent
Through: Ms. Meenakshi Dahiya, APP
Insp. Sanjay Kaushik, NR-1,
Signature Not Verified
Signed By:BHARTI
Signing Date:04.11.2026
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CRL.REV. P. 29/2020 and connected matters Page 1 of 52

Crime Branch.
# CNR No. DLHC010187932022
+ CRL.REV.P. 297/2022
STATE OF NCT OF DELHI .....Petitioner
Through: Ms. Meenakshi Dahiya, APP
Insp. Sanjay Kaushik, NR-1, Crime
Branch
versus
MAYANK SINGHVI & ORS. .....Respondents
Through: Mr. Siddharth Aggarwal, Sr. Adv.
and Mr. Amit Chadha, Sr. Adv., Mr.
Pankaj Baghla, Ms. Vismita Diwam,
Mr. Gurpreet Singh, Mr. Siddhant
Saraswat, Mr. Manjit Walia and Mr.
Harjas Singh, Advs..
CORAM:
HON'BLE MS. JUSTICE MADHU JAIN
JUDGMENT
MADHU JAIN, J.
1. The present revision petitions arise out of the order dated 18.12.2019
passed by the learned Additional Sessions Judge-02 (South), Saket Courts,
New Delhi, in Sessions Case No. 676/2018 , titled State v. Mayank Singhvi .
The said Sessions Case arose from FIR No. 185/2018 registered at Police
Station Hauz Khas, South District, Delhi. The impugned order, concerns the
offences punishable under Sections 304B, 498A, 306 read with Section 34 of
the Indian Penal Code, 1860 (hereinafter referred to as ‘IPC’).
2. The result of the impugned order and the scope of the three revision
petitions may be noticed separately.
Outcome of the Impugned order dated 18.12.2019
ACCUSED RESULT UNDER
Section 304B read with Section 34
Mayank Singhvi Discharged
IPC
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ACCUSED RESULT UNDER
Charges directed
Mayank Singhvi Sections 498A and 306 IPC
to be framed
Rajender Singh
Singhvi &
Sushma Singhvi
Sections 304B and 498A read with
Discharged
Section 34 IPC
Scope of the present revision petitions
PETITIO
N
PETIT
IONER
RELATI
SCOPE OF CHALLENGE
ON
Discharge of Mayank Singhvi under
Section 304B read with Section 34 IPC
and of Rajender Singh Singhvi and
Sushma Singhvi under Sections 304B
and 498A read with Section 34 IPC.
Mother
of the
deceased
CRL.REV.
P. 29/2020
Nillum
Batra
CRL.REV.
P. 170/2021
Mayank
Singhvi
Husband/
Accused
Direction to frame charges under
Sections 498A and 306 IPC.
Discharge of Mayank Singhvi under
Section 304B read with Section 34 IPC
and of Rajender Singh Singhvi and
Sushma Singhvi under Sections 304B
and 498A read with Section 34 IPC.
State
(NCT
of
Delhi)
CRL.REV.
P. 297/2022
Prosecuti
on
3. All three petitions arise from the same FIR, the same Sessions Case and
the same order on charge. Since their determination requires consideration of
the common material collected during investigation, they were heard together
and are being decided vide this common judgment.
FACTUAL BACKGROUND
4. The facts leading to the present batch of petitions are that Anissia Batra
(hereinafter referred to as ‘the deceased’), daughter of Nillum Batra and R.S.
Batra, got engaged to Mayank Singhvi, son of Rajender Singh Singhvi and
Sushma Singhvi, on 29.09.2015 and both were later married on 23.02.2016.
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5. Upon their marriage, the deceased and Mayank Singhvi initially resided
in a rented accommodation at Safdarjung Development Area, New Delhi,
whereafter, they later shifted to the first floor of property bearing No. N-116,
Panchsheel Park, New Delhi which was owned by Mayank Singhvi’s parents,
who resided separately from the couple.
6. According to the prosecution and the complainant, the matrimonial
relationship became strained soon after their marriage. The first incident
relied upon is stated to have occurred during the couple’s honeymoon at Dubai
in March 2016, when Mayank Singhvi allegedly assaulted the deceased after
which she contacted her mother. Her parents state, that when the aforesaid
incident was taken up with Mayank Singhvi’s parents, they attributed it to the
conduct of the deceased itself.
7. Alongside the allegations of physical cruelty, the parents of the
deceased alleged, that monetary demands were raised before and after the
marriage. Their statements refer to a demand of ₹10 lakh, payment of
approximately ₹2 lakh to Mayank Singhvi at the time of the marriage, ten gold
guineas, jewellery and expensive clothes allegedly given to him and his
relatives, and a further amount of approximately ₹3 lakh allegedly advanced
to him by the deceased. According to the prosecution, some of these demands
were described as financial assistance for Mayank Singhvi.
8. The allegations continued throughout 2016 and 2017. In July 2016,
Mayank Singhvi is alleged to have again behaved violently towards the
deceased whereafter her father met her in-laws i.e. Rajender Singh Singhvi
and Sushma Singhvi, who allegedly expressed dissatisfaction with the manner
in which the concerned marriage had been performed and reiterated the
demand for financial assistance. A similar demand is stated to have been made
during the first wedding anniversary celebrations on 23.02.2017. The
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prosecution also relies upon an incident dated 12.04.2017, when Mayank
Singhvi allegedly abused and assaulted the deceased. The deceased is stated
to have informed Sushma Singhvi of the aforesaid incident, but her account
was allegedly not accepted.
9. The relationship is stated to have deteriorated further during May and
June 2018. Nillum Batra, the mother, came to Delhi on 05.06.2018 to stay
with the deceased. On the following day, Mayank Singhvi allegedly behaved
violently towards the deceased and her mother while speaking to his mother
over the telephone. The complainant alleges that he was being instigated by
his mother. It is further alleged that, after Mayank Singhvi’s parents returned
from abroad, the deceased and her mother were asked to vacate the
matrimonial home and that Rajender Singh Singhvi threatened that the
deceased could be made to disappear.
10. The dispute during this period also concerned a flat at Vasant Kunj,
jointly owned by the deceased and her mother. According to the parents of
the deceased, the accused persons pressurised her to sell the flat and hand over
the sale proceeds to them. The sale is stated to have been completed on or
around 12.06.2018. The complainant maintains that the matrimonial discord
escalated when the sale proceeds were not made available to the accused
persons.
11. During the same period, the deceased placed her concerns on record.
On 23.06.2018, she addressed an email to her counsel setting out allegations
concerning her matrimonial relationship. Four days later, on 27.06.2018, her
father submitted a complaint at Police Station Hauz Khas expressing
apprehension for her safety and alleging physical violence and threats at the
matrimonial home. The prosecution also relies upon WhatsApp messages
exchanged between the deceased and her family, including messages dated
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06.07.2018 in which she objected to the involvement of Mayank Singhvi’s
parents in the matrimonial dispute.
12. The accused persons however, dispute these allegations. They maintain
that the couple had been provided a separate residence so that they could live
independently. Mayank Singhvi states that he and the deceased lived apart
from about 07.06.2018 to 07.07.2018 and considered an amicable separation.
According to him, following an intervention by relatives and well-wishers,
they decided to make another effort to preserve the marriage, obtain
counselling and reside in separate rooms in the same house. He claims to have
returned to the matrimonial residence on or around 08/09.07.2018.
13. It is against this background that the incident dated 13.07.2018
occurred. On that day, the deceased sustained fatal injuries after falling from
the terrace of the matrimonial residence. Mayank Singhvi states that she had
gone to the terrace at about 2:00-2:30 p.m., whereupon he followed her and
persuaded her to return downstairs. He further states that a dispute arose later
that afternoon concerning access to his electronic account and certain personal
relationships of the deceased.
14. The prosecution relies upon messages allegedly sent by the deceased
shortly before the incident. At about 2:56 p.m., she is stated to have informed
her friend Seema Malik that Mayank Singhvi had locked her in, and further
requested that the police be called. At about 4:12 p.m., she allegedly sent a
message to Seema Malik stating, inter alia , that “I am going to kill myself
today bcoz Mayank has driven me to it. He finally let me out but I can’t repair
what he has done . ” A similar message was also sent by the deceased to her
counsel.
15. Mayank Singhvi, on the other hand, states that the deceased sent him a
message asking him to come to the terrace. According to him, he rushed
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upstairs but found the terrace door locked from the other side. He claims to
have gained entry after breaking through a side grill. Upon being informed by
persons present in a neighbouring building that the deceased had fallen, he
went downstairs and took her to Max Hospital, Panchsheel Park.
16. The deceased was brought to the hospital in an unconscious condition
and was subsequently declared dead. At about 6:27 p.m., information
regarding her death was received at Police Station Hauz Khas vide DD No.
40A . The post-mortem examination attributed the cause of death to shock
consequent upon multiple fatal injuries caused by blunt-force impact. Mayank
Singhvi relies upon the viscera report, which recorded ethyl alcohol
measuring 298 mg per 100 ml of blood, and contends that the possibility of
an accidental fall could not be excluded.
17. On the following day, i.e. 14.07.2018, the statements of the parents of
the deceased were recorded before the Sub-Divisional Magistrate. On the
basis of the statement made by Nillum Batra, FIR No. 185/2018 was
registered at Police Station Hauz Khas for the offence punishable under
Section 304B IPC. Nillum Batra alleged, that Mayank Singhvi had repeatedly
demanded money from the deceased and held him and his parents responsible
for her daughter’s death.
18. The parents of the deceased thereafter made supplementary statements.
They gave further particulars concerning the alleged demands of money and
jewellery, the acts of violence attributed to Mayank Singhvi, the alleged
involvement of his parents, the pressure concerning the Vasant Kunj property
and the threats allegedly extended to the deceased and her family. The
investigating agency also recorded the statements of relatives, friends,
neighbours and other persons acquainted with the parties.
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19. On 16.07.2018, notices under Section 41A of the Code of Criminal
Procedure, 1973 [hereinafter referred to as ‘CrPC’] were served upon Mayank
Singhvi and his parents, whereafter, he was arrested on the very same day.
The investigation was subsequently transferred to the Crime Branch, while
Rajender Singh Singhvi and Sushma Singhvi later surrendered before the
concerned Sessions Court.
20. During investigation, the mobile phones, laptop and other electronic
devices connected with the parties were seized. The investigating agency also
collected WhatsApp messages, emails, CCTV footage, bank records and other
digital material. The electronic devices were sent for forensic examination,
and the material retrieved therefrom was subsequently placed before the
concerned learned Trial Court.
21. Upon completion of the initial investigation, a charge-sheet dated
12.10.2018 was filed against Mayank Singhvi, Rajender Singh Singhvi and
Sushma Singhvi for the offences punishable under Sections 304B and 498A
read with Section 34 IPC. A supplementary charge-sheet was also filed on
31.10.2018 after receipt of further medical material. The forensic reports
concerning the electronic devices and other supplementary material were also
placed on record.
22. The case was committed to the Court of Sessions on 15.11.2018 and
was registered as Sessions Case No. 676/2018 . The prosecution, the
complainant and the accused persons thereafter addressed arguments on the
question of charge.
23. While considering the material on record, the learned Trial Court
observed that no allegation of demand for dowry against Rajender Singh
Singhvi and Sushma Singhvi was discernible from the FIR, the email dated
23.06.2018, the complaint dated 27.06.2018 or the contemporaneous
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WhatsApp messages. It also noted that they resided separately from the couple
and found no sufficiently specific material disclosing cruelty or harassment
by them in connection with a demand for dowry.
24. Insofar as Mayank Singhvi is concerned, the learned Trial Court found
that the contemporaneous material contained allegations of assault and
matrimonial cruelty but did not disclose the necessary connection between
such cruelty and a demand for dowry. It nevertheless took note of the
allegations of assault and the last communication of the deceased attributing
her alleged decision to him. Having regard to that material and the
presumption contemplated under Section 113A of the Indian Evidence Act,
1872 (hereinafter referred to as ‘Evidence Act’), the learned Trial Court
passed the directions reflected in the table at the outset.
25. Notice in CRL.REV. P. 29/2020 was issued on 16.01.2020. Thereafter,
notice in CRL.REV. P. 170/2021 was issued on 09.04.2021, when Nillum
Batra was impleaded as respondent No. 2, and both petitions were directed to
be listed together. Notice in CRL.REV. P. 297/2022 was issued on 17.05.2022
and the said petition was directed to be listed along with the other two
petitions. Vide order dated 24.08.2022, the delay of 688 days in filing the
State’s petition was condoned.
SUBMISSIONS ADVANCED
On behalf of Nillum Batra, the complainant
26. Ms. Rebecca M. John, learned Senior Counsel appearing for Nillum
Batra in CRL.REV.P. 29/2020 , and Mr. Vishal Gosain, learned Senior
Counsel who subsequently appeared for the same in the connected petitions,
assailed the discharge of Mayank Singhvi under Section 304B read with
Section 34 IPC and the discharge of Rajender Singh Singhvi and Sushma
Singhvi under Sections 304B and 498A read with Section 34 IPC. It was
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submitted that the learned Trial Court had tested the prosecution material as
though it were finally adjudicating the case, instead of determining whether
the material, taken at its face value, raised a grave suspicion requiring the
accused persons to stand trial.
27. Learned Senior Counsel submitted that, at the stage of charge, the Court
may sift the material only for the limited purpose of ascertaining whether a
prima facie case is disclosed and that it cannot undertake a roving enquiry,
test the credibility of witnesses or decide whether the prosecution would
ultimately secure a conviction. Reliance was placed upon Sajjan Kumar v.
CBI, (2010) 9 SCC 368 , and Sukh Chand v. State (NCT of Delhi), 2026 SCC
OnLine Del 6287 , to submit that contradictions, improvements and the weight
to be attached to later statements are matters for trial where the record
otherwise discloses the ingredients of the alleged offences.
28. It was submitted that the first statement of Nillum Batra recorded before
the Sub-Divisional Magistrate itself alleged that Mayank Singhvi repeatedly
demanded money from the deceased. That the complaint dated 27.06.2018,
lodged while the deceased was alive, expressed an apprehension for her safety
and referred to violence and threats at the matrimonial home. The
supplementary statements of the parents were stated to furnish further
particulars of the same course of conduct and could not be discarded merely
because they were recorded later, particularly when the parents had made the
initial statements immediately after their daughter’s death and while they
were stated to be in shock.
29. Learned Senior Counsel referred to the allegations that ₹10 lakh had
been demanded before the marriage, that about ₹2 lakh, ten gold guineas,
jewellery and expensive clothes had been given at the time of the marriage,
that a demand for financial assistance was repeated by the parents of Mayank
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Singhvi in July 2016 and at the first wedding anniversary and that the accused
persons later pressurised the deceased to sell the Vasant Kunj flat and part
with its sale proceeds. It was contended that the description of a demand as
financial assistance did not take it outside the scope of dowry if the
surrounding facts showed its connection with the marriage and the alleged
cruelty.
30. It was further submitted that the role attributed to Rajender Singh
Singhvi and Sushma Singhvi was neither general nor peripheral. That the
parents of the deceased had alleged that they blamed the deceased after
incidents of physical violence, reiterated monetary demands, encouraged
Mayank Singhvi, asked the deceased and her mother to vacate the matrimonial
home and threatened dire consequences. The statement of Kanchan Sharma
and the WhatsApp exchange dated 06.07.2018, in which the deceased
objected to the involvement of Mayank Singhvi’s parents, were also relied
upon as corroborative material.
31. It was accordingly contended that the death had occurred within seven
years of the marriage and that the statements of the parents, the complaint
dated 27.06.2018, the email dated 23.06.2018, the WhatsApp
communications, the bank material and the statements collected during
investigation, when considered cumulatively, disclosed sufficient grounds to
frame charges. The petitioner i.e. the complainant, therefore, prayed that the
impugned order be set aside to the extent that it discharged Mayank Singhvi
under Section 304B IPC and discharged Rajender Singh Singhvi and Sushma
Singhvi under Sections 304B and 498A IPC.
On behalf of the State
32. Learned APP for the State supported the challenge to the impugned
orders and relied upon the charge-sheets and the statements recorded during
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investigation. It was submitted that an FIR or a statement recorded
immediately after the incident was not required to contain an exhaustive
account of every prior demand or incident, and that the supplementary
statements were required to be read as elaborating upon the allegation of
repeated monetary demands already contained in the first statement.
33. The State relied, in particular, upon the alleged demands of ₹10 lakh,
the payments and articles stated to have been given at the time of marriage,
the alleged pressure concerning the Vasant Kunj property, the incidents of
physical violence, the allegation that the parents of Mayank Singhvi had
instigated or supported his conduct, and the proximity between the later
events and the death. It was contended that this material, if accepted at its face
value, disclosed the ingredients necessary to proceed to trial and that the
learned Trial Court had impermissibly preferred the defence explanation
while considering charge.
34. The State, therefore, prayed that the discharge of all three accused
persons under Section 304B IPC and the discharge of Rajender Singh Singhvi
and Sushma Singhvi under Section 498A IPC be set aside and that appropriate
charges be directed to be framed in accordance with the material collected
during investigation.
On behalf of Mayank Singhvi and the other accused persons
35. Per contra , Mr. Siddharth Aggarwal and Mr. Amit Chadha, learned
Senior Counsel(s) appearing for Mayank Singhvi and the other accused
persons, supported the discharge of Rajender Singh Singhvi and Sushma
Singhvi and assailed the direction to frame charges against Mayank Singhvi
under Sections 498A and 306 IPC. It was submitted that the contemporaneous
record disclosed a troubled matrimonial relationship and mutual altercations,
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but did not disclose dowry-related cruelty or any act amounting to abetment
of suicide.
36. Learned Senior Counsel(s) submitted that the prosecution case
substantially rested upon the email dated 23.06.2018 sent by the deceased to
her counsel and the WhatsApp messages allegedly sent to her friend Seema
Malik and her counsel on 13.07.2018. The devices of the recipients were
stated not to have been seized, while the mobile phone of the deceased was
stated to have remained password protected and not to have been unlocked.
The attribution, completeness, authenticity and context of the electronic
communications were therefore questioned. It was further submitted that the
email dated 23.06.2018 was written for obtaining legal advice in
contemplation of matrimonial proceedings and was not, by itself, a
declaration concerning the cause of death.
37. It was contended that neither the email dated 23.06.2018, the complaint
dated 27.06.2018 nor the contemporaneous WhatsApp communications
contained any demand for dowry by Rajender Singh Singhvi or Sushma
Singhvi. According to the learned Senior Counsels, the later allegations
regarding ₹10 lakh, the jewellery, the sale proceeds of the Vasant Kunj flat
and the involvement of the parents-in-law, were all material improvements
unsupported by contemporaneous documentary or financial evidence.
38. The defence placed emphasis upon the fact that the marriage was a love
marriage between two adults who had known each other before marriage. It
was submitted that the parents of Mayank Singhvi had provided the couple
with a separate residence at Panchsheel Park and did not reside with them.
They were stated to have been abroad during a material part of the
matrimonial discord and to have returned only after being called. Their
absence from the matrimonial home and the lack of any specific
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contemporaneous allegation against them were relied upon to submit that they
had been implicated solely on account of their relationship with Mayank
Singhvi.
39. It was further submitted that the financial conduct of Mayank Singhvi
was inconsistent with a demand for dowry. The defence referred to the BMW
vehicle purchased for the deceased upon a loan stated to have been serviced
by Mayank Singhvi even after her death, a diamond ring stated to have been
purchased for about ₹16 lakh, regular transfers of approximately ₹35,000 per
month and an offer to contribute towards a property to be acquired in the
deceased’s own name. These circumstances were relied upon to contend that
the allegations of financial exploitation were inherently improbable.
40. As regards the Vasant Kunj flat, the learned Senior Counsel submitted
that its sale proceeds remained with the deceased and her family and were not
transferred to any of the accused persons. The communications concerning
purchase of another property were stated to show that any contribution
proposed by Mayank Singhvi was intended for a property in the deceased’s
name. It was contended that the prosecution had converted financial
discussions between the spouses and the deceased’s family into an allegation
of dowry demand without any supporting transaction.
41. Learned Senior Counsel further relied upon the chronology
immediately preceding the incident. Mayank Singhvi and the deceased were
stated to have lived apart from about 07.06.2018 until 08/09.07.2018 while
discussions for an amicable separation continued. Mayank Singhvi returned
to the matrimonial home only a few days before the incident dated
13.07.2018. It was submitted that the record did not disclose any positive or
proximate act during this interval by which the deceased had been instigated
or intentionally aided to take her life.
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42. The reliability of the messages allegedly sent on 13.07.2018 was also
questioned. It was submitted that the messages were exchanged between
Seema Malik and the deceased between approximately 2:56 and 2:58 pm,
whereas the incident occurred after 4:00 p.m., yet neither Seema Malik nor
the counsel who later received a message contacted the police. The deceased
herself had access to her mobile phone. The defence also referred to the
configuration of the room and to the statement of the domestic help to dispute
the assertion that the deceased had been confined. According to the defence,
isolated messages could not be read without the preceding and subsequent
communications, including the message asking Mayank Singhvi to come to
the roof.
43. The statements of Raj Kumar and Naveen Kumar, who were stated to
have witnessed the fall, were relied upon to submit, that the deceased was on
the other side of the terrace railing with a mobile phone and may have slipped
while attempting to take a photograph. Learned Senior Counsel also relied
upon Mayank Singhvi’s immediate conduct in taking the deceased to the
hospital. The viscera report, which recorded ethyl alcohol measuring 298 mg
per 100 ml of blood, and medical literature concerning the effect of such
intoxication upon judgment and motor control were cited in support of the
alternative possibility of an accidental fall.
44. The defence further referred to communications between the deceased
and her mother concerning stress, depression, medication, alcohol
consumption and episodes of emotional dysregulation, as well as material
relating to an alleged earlier attempt at self-harm. It was submitted that these
communications also recorded occasions when the deceased’s mother
appreciated the conduct of Mayank Singhvi and his family and sought to calm
the deceased. According to the learned Senior Counsels, this material showed,
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that the unfortunate incident could not be attributed to a unilateral course of
cruelty by the accused persons.
45. In relation to Section 498A IPC, it was submitted that neither limb of
the said provision was attracted. That there was no contemporaneous material
connecting the alleged conduct with a demand for property so as to attract
Explanation (b), and that the allegations of marital quarrels and mutual
altercations also did not constitute the wilful conduct of the nature
contemplated under Explanation (a). The learned Trial Court was therefore
stated to have erred in directing a charge under Section 498A IPC against
Mayank Singhvi after itself finding no dowry nexus.
46. In relation to Section 306 IPC, the learned Senior Counsel submitted
that the prosecution material did not disclose instigation, conspiracy or
intentional aid within the meaning of Section 107 IPC. It was also argued that
neither the original nor the supplementary charge-sheet proposed an offence
under Section 306 IPC and that the impugned order did not identify any new
material warranting its invocation. Matrimonial discord, harsh words or a
message in which the deceased blamed Mayank Singhvi, without a positive
and proximate act intended to bring about the suicide, were stated to be
insufficient to constitute abetment. It was contended that the statutory
presumption under Section 113A of the Evidence Act did not dispense with
the need to establish the foundational facts and could not substitute proof of
abetment.
47. It was accordingly prayed that CRL.REV. P. 29/2020 and CRL.REV.
P. 297/2022 be dismissed and that the discharge of Rajender Singh Singhvi
and Sushma Singhvi be affirmed. Mayank Singhvi prayed that CRL.REV. P.
170/2021 be allowed and that the impugned order be set aside to the extent
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that it directed charges to be framed against him under Sections 498A and 306
IPC.
Submissions in rebuttal
48. In rebuttal, learned counsel for the complainant and the State submitted
that the defence was inviting the Court to finally determine disputed questions
of authenticity, credibility and causation at the stage of charge. The
supplementary statements could not be excluded at the threshold merely
because they contained further particulars, and the question whether they were
improvements or reliable elaborations of the first statement could be tested
only after evidence was led.
49. It was further submitted that alleged omissions in investigation,
including the non-seizure of certain devices, could not by themselves confer
a right to discharge where the remaining prosecution material disclosed a
grave suspicion. The defence pleas concerning an accidental fall, alcohol
consumption, mental health, prior conduct and the interpretation of electronic
communications were stated to be matters requiring trial and could not be
accepted conclusively at this stage. Insofar as the charge under Section 306
IPC was concerned, it was urged that the presumption under Section 113A of
the Evidence Act was a relevant statutory circumstance, subject to proof of its
foundational facts, and could not be neutralised by conducting a mini-trial at
the stage of charge.
ANALYSIS AND FINDINGS
50. This Court has heard the respective learned counsel(s) appearing on
behalf of the concerned parties and has also perused the material placed on
record.
51. The principal issues which arise for consideration are, first, whether the
discharge of the revisionist Mayank Singhvi under Section 304B of IPC and
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the discharge of Rajender Singh Singhvi and Sushma Singhvi under Sections
304B and 498A read with Section 34 of IPC call for any interference by this
Court in exercise of its revisional jurisdiction, and second, whether the
material placed on record discloses any sufficient ground to proceed against
Mayank Singhvi under Sections 498A and 306 of IPC.
52. Although these petitions arise from the same matrimonial relationship,
death and investigation, each assails a distinct part of the order on charge, and
the offences involved have separate statutory ingredients. They will therefore
be considered, offence-wise. But before undertaking the aforesaid exercise,
this Court deems it appropriate to delineate the scope of its revisional
jurisdiction and the circumstances in which it may interfere with an order
framing charge and discharge an accused to prevent a miscarriage of justice.
Scope of interference with an order on charge
53. The jurisdiction of the High Court under Sections 397 and 401 CrPC is
supervisory and corrective in nature. It is concerned with the correctness,
legality and propriety of the impugned order and the regularity of the
proceedings. It does not permit an appellate reassessment of the material
merely because another view might be possible. In Amit Kapoor v. Ramesh
Chander, (2012) 9 SCC 460 , the Supreme Court explained that revisional
interference is warranted where an order suffers from a patent defect or an
error of jurisdiction or law, ignores material evidence, rests on no evidence,
or reflects an arbitrary or perverse exercise of judicial discretion. These
limitations govern the interference with an order on charge as well. But this
restraint required of a revisional court, does not place such an order beyond
scrutiny where the legal foundation for proceeding against the accused is itself
in question. This scrutiny must be undertaken within the framework of
Sections 227 and 228 of CrPC.
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54. The Court is not required to determine the guilt, or ascertain, whether
the prosecution will ultimately secure a conviction or not. But it must satisfy
itself, that the material before the Court provides sufficient ground(s) for
proceeding against the concerned accused. As explained in Amit Kapoor v.
Ramesh Chander (supra) , satisfaction concerning the existence of the
ingredients of the offence and the facts supporting them is a necessary
condition for framing a charge. Such is because the tentative nature of the
opinion of the Court concerned at this stage i.e. the stage of framing of charge,
no doubt dispenses with the requirement of proof beyond reasonable doubt,
but, it does not in any case dispense with the requirement of a factual
foundation for the offence alleged against the concerned accused.
55. In Union of India v. Prafulla Kumar Samal, (1979) 3 SCC 4 , the
Supreme Court recognised the power of the Court to sift through, and weigh
the material for the limited purpose of determining, whether a prima
facie case exists or not. It was observed that the Court in such cases must
consider the broad probabilities, the cumulative effect of the material and any
basic infirmities appearing from the record. That it cannot merely endorse the
conclusion of the investigating agency. The same decision also recognises,
that where two views are equally possible and the material gives rise only to
some suspicion, as distinguished from grave suspicion, discharge is justified.
This does not however, authorise a roving enquiry or the weighing of evidence
as at the conclusion of a trial. What it requires is an independent judicial
assessment of whether the threshold for putting the accused on trial has been
crossed or not.
56. In Sajjan Kumar v. CBI (supra) , the Supreme Court further explained
the nature of this enquiry. The following observations are relevant:
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“(vi) At the stage of Sections 227 and 228, the court is
required to evaluate the material and documents on record
with a view to find out if the facts emerging therefrom
taken at their face value disclose the existence of all the
ingredients constituting the alleged offence. For this
limited purpose, sift the evidence as it cannot be
expected even at that initial stage to accept all that the
prosecution states as gospel truth even if it is opposed
to common sense or the broad probabilities of the case.
(vii) If two views are possible and one of them gives rise
to suspicion only, as distinguished from grave
suspicion, the trial Judge will be empowered to
discharge the accused and at this stage, he is not to see
whether the trial will end in conviction or acquittal. ”
(Emphasis supplied)
57. In State of M.P. v. Sheetla Sahai, (2009) 8 SCC 617 , the Supreme
Court held that the material brought on record by the prosecution must be
considered in its entirety, including material favourable to the accused. Such
consideration is distinct from examining independent defence material, which
does not ordinarily form part of the enquiry under Sections 227 and 228 CrPC.
This distinction was reiterated in Vishnu Kumar Shukla v. State of U.P.,
(2023) 15 SCC 502 . Read together, these principles require the suspicion,
which should be grave in nature, to arise from material supporting the
ingredients of the alleged offence. The ‘seriousness of an accusation’ cannot
substitute for the aforesaid requirement.
58. Revisional interference is therefore justified, where the learned Trial
Court has applied an incorrect legal test, overlooked an essential ingredient or
material circumstance, or treated conjecture as grave suspicion, and such error
materially affects the decision to frame the charge. If, upon correcting that
error and examining the record within the permissible limits, no sufficient
ground for proceeding remains, the High Court may set aside the order on
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charge and discharge the accused in respect of the offence concerned. The
accused is not required to establish innocence at this stage.
59. In Dilawar Balu Kurane v. State of Maharashtra, (2002) 2 SCC 135 ,
the Supreme Court applied these principles and set aside the impugned
judgment, finding that the courts below had failed to apply their minds to the
material and that no prima facie case existed. Further, in Vishnu Kumar
Shukla v. State of U.P. (supra) , the Supreme Court emphasised the duty of
the High Courts, in deserving cases, to protect an accused from an
unwarranted prosecution and the unnecessary rigours of a trial. Once the
absence of sufficient ground to proceed is established through the scrutiny
permitted by law, continuation of the prosecution cannot be justified merely
because the proceedings have reached the stage of charge.
60. The question in the present revisions is accordingly, whether the
concerned learned Trial Court applied the correct legal standard and whether
the material on record furnishes sufficient ground to proceed against the
concerned accused for the offences that he has been charged with, and
whether the same material furnishes sufficient ground to discharge those
accused persons who already stand discharged vide the impugned order.
61. Now the WhatsApp communications and emails which are going to be
referred to below, were placed with the charge-sheet and were considered by
the concerned learned Trial Court without objection from the parties. So they
are also being considered here only as material forming part of the
prosecution’s record. This Court is neither certifying their proof nor finally
resolving disputed questions of credibility. It is nevertheless necessary to read
the communications as a whole, as an inculpatory extract cannot be isolated
while the surrounding material collected in the same investigation is excluded.
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Section 304B IPC
62. Section 304B IPC, read with Section 113B of the Evidence Act,
requires the prosecution material to disclose, that the death occurred otherwise
than under normal circumstances within seven years of marriage and that,
soon before her death, the woman was subjected by her husband or his relative
to cruelty or harassment for, or in connection with, a demand for dowry. These
are foundational facts which must be disclosed, as the statutory presumption
under Section 113B of the Evidence Act arises only upon their disclosure and
cannot be invoked to supply an ingredient otherwise absent from the record.
Reference in this regard may be made to Baijnath v. State of M.P., (2017) 1
SCC 101 .
63. The expression ‘dowry’ is not confined to a demand which is made at
the time of, or before the marriage. A post-marriage demand may also fall
within its ambit, provided that it bears a reasonable connection with the
marriage. Conversely, every financial dealing or demand arising during the
subsistence of a marriage does not, for that reason alone, assume the character
of dowry. The requisite nexus must emerge from the nature of the demand
and the surrounding circumstances. Likewise, the expression ‘soon before’
does not prescribe a fixed interval. It requires a proximate and live link
between the dowry-related cruelty or harassment and the death. A demand
which is remote, stale or unconnected with the circumstances leading to the
death would not satisfy this requirement. Reference in this regard may be
made to Kans Raj v. State of Punjab, (2000) 5 SCC 207 , Rajinder Singh v.
State of Punjab, (2015) 6 SCC 477 , Satbir Singh v. State of Haryana, (2021)
6 SCC 1 and State of M.P. v. Jogendra, (2022) 5 SCC 401 .
64. These distinctions, assume significance in the present petitions. The
occurrence of an unnatural death within seven years of marriage, even when
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accompanied by allegations of matrimonial cruelty, does not by itself attract
Section 304B of IPC. The material must additionally disclose that the cruelty
or harassment was connected with a demand for dowry and bore the required
proximity to the death. In Chabi Karmakar v. State of W.B., (2025) 1 SCC
398 , the Supreme Court, maintained the distinction between cruelty
attributable to other causes and cruelty connected with a demand for dowry.
At the stage of charge, the Court is not required to determine whether these
ingredients stand proved beyond reasonable doubt, but it must however, be
satisfied, that the material taken at its face value and considered cumulatively,
raises grave suspicion as to the existence of each of them. Neither the
seriousness of the allegations nor the statutory presumption can compensate
for the absence of the dowry nexus or the proximate link required by Section
304B of IPC.
Mayank Singhvi (Husband)
65. Applying these principles to the present case, it is undisputed that the
death occurred otherwise than under normal circumstances and within seven
years of marriage. The applicability of Section 304B IPC must therefore, turn
on, whether the police-report material, taken at its face value and considered
cumulatively, discloses that Mayank Singhvi subjected the deceased, soon
before her death, to cruelty or harassment for, or in connection with, a demand
for dowry. The contemporaneous material forming part of the record assumes
particular significance in this regard.
66. The email dated 23.06.2018, addressed by the deceased to her counsel,
constitutes the most detailed contemporaneous first-person account forming
part of the record. It contains serious allegations of assault and matrimonial
misconduct against Mayank Singhvi, but despite its detail and the fact that it
was written for obtaining legal advice, the email does not refer to any demand
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for dowry, any demand for the proceeds of the Vasant Kunj flat, or any
harassment intended to compel the transfer of those proceeds. The learned
Trial Court correctly regarded this omission as being material to the distinct
statutory requirement of a dowry nexus.
67. The contemporaneous communications concerning the Vasant Kunj
property are consistent with this assessment. On 27.02.2018, the deceased
described the proposed sale as an attractive transaction, stated that she had
time to decide how the sale proceeds were to be utilised, and explained that
any property acquired through a joint investment with Mayank Singhvi would
stand in her name. She wrote that, “Even if it’s in both our names the property
would be worth in crores and he would be putting in the bulk share. So it’s
still a win. But he wants to buy in my name.” This was followed by her another
statement, that, “Don’t worry. I have thought about it. I’m completely
guarding my financial investments”.
68. The Court must decide on the basis of what’s before it without making
any assumptions as to whether something else could’ve happened or not. The
relevance of the aforesaid statements lies in the fact that the deceased’s own
contemporaneous account does not disclose any existing obligation to
surrender the sale proceeds. On the contrary, it records the commercial
considerations underlying the proposed sale, the alternatives available for
reinvestment, and her intention to retain control over the proceeds and protect
her title in any future investment.
69. The exchange between Mayank Singhvi and Nillum Batra in April
2018 again points in the same direction. Mayank Singhvi wrote that, “I will
give her the house” , “Will take in her name and give it to her” and “Will give
1 CR and she can buy it in her name.” Nillum Batra responded, that, “That’s
very generous of u Mayank. We’ll talk when we meet”. Other
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communications forming part of the record also refer to an agreement to bear
the rent for separate accommodation, an express option that the deceased need
not sell her apartment, and proposals for financial support. On 26.06.2018,
the deceased herself stated that a major part of the money had been utilised
towards repayment of her father’s loans. No transaction forming part of the
police-report material has been identified as showing that the proceeds of the
Vasant Kunj property were received by Mayank Singhvi or his parents.
70. The subsequent statements alleging demands of ₹10 lakh, payments
made at the time of marriage, gold guineas, jewellery and pressure concerning
the Vasant Kunj property have also been considered. They cannot be
discarded merely because further particulars were furnished at a later stage,
but even when taken at their highest, those allegations must disclose a
proximate link between the cruelty or harassment alleged soon before the
death and a demand for dowry, and such a link, does not emerge from the
detailed email of the deceased to her counsel, the contemporaneous property
communications, the exchanges immediately preceding the death, or the
financial material collected during the investigation.
71. The learned Trial Court, therefore, correctly held that although the
material discloses a seriously strained matrimonial relationship, it does not
disclose cruelty or harassment for, or in connection with, a demand for dowry.
Neither the occurrence of an unnatural death within seven years of marriage
nor the presumption under Section 113B of the Evidence Act can supply this
indispensable statutory ingredient. The discharge of Mayank Singhvi under
Section 304B IPC, is therefore liable to be affirmed.
Rajender Singh Singhvi and Sushma Singhvi (In-Laws)
72. The material concerning Rajender Singh Singhvi and Sushma Singhvi
must also be examined independently, with reference to the acts specifically
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attributed to each of them. Their separate residence from the matrimonial
couple is not, by itself, determinative of whether they prima facie committed
the offences alleged against them or not. But it nevertheless assumes
relevance, where the allegations concerning their participation in the
matrimonial discord are collective in nature and lack particulars identifying
the conduct of either of them.
73. Viewed in this light, neither the email dated 23.06.2018 nor the
complaint dated 27.06.2018 attributes to either parent-in-law any demand for
dowry, act of assault, or coercion concerning the proceeds of the Vasant Kunj
property. The messages dated 06.07.2018 indicate that the deceased objected
to their involvement in the matrimonial dispute. They do not, however,
identify any specific act committed by either parent-in-law that would
disclose dowry-related cruelty or harassment soon before the death.
74. The supplementary statements refer to dissatisfaction with the manner
in which the marriage was performed, requests for financial assistance,
support allegedly extended to Mayank Singhvi, pressure concerning the
Vasant Kunj property, and an alleged threat. These allegations when taken at
their face value, remain substantially collective and do not in the opinion of
this Court prima facie disclose the commission of the offence under Section
304B IPC by Rajender Singh Singhvi and Sushma Singhvi. The material
accompanying the charge-sheet also does not identify any contemporaneous
communication or transaction connecting either of them with a demand for
the sale proceeds, or with harassment employed to enforce such a demand in
proximity to the death.
75. The invocation of Section 34 IPC cannot compensate for the absence
of foundational material against a particular accused. Common intention
becomes relevant only when the record first discloses participation by the
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accused in an act constituting the alleged offence. Mere relationship with the
husband, or general support allegedly extended to him in a matrimonial
dispute, does not satisfy that requirement.
76. The learned Trial Court considered these circumstances and found no
specific material disclosing that Rajender Singh Singhvi or Sushma Singhvi
had subjected the deceased to cruelty or harassment for, or in connection with,
a demand for dowry. This Court finds no error in that conclusion. Their
discharge under Section 304B read with Section 34 IPC, therefore, calls for
no interference and is liable to be affirmed.
Section 306 IPC
77. Section 306 of IPC does not punish suicide simpliciter. It punishes the
abetment of suicide. The expression ‘abetment’ must be understood in the
light of Section 107 IPC, which contemplates three distinct modes. Instigation
to do the act, engagement in a conspiracy followed by an act or illegal
omission in pursuance thereof, or intentional aid by an act or illegal omission.
Therefore, even at the stage of charge, the material, taken at its face value,
must disclose a factual foundation for at least one of these modes against the
accused concerned.
78. In Ramesh Kumar v. State of Chhattisgarh, (2001) 9 SCC 618 , the
Supreme Court explained, that ‘instigation’ means to goad, urge forward,
provoke, incite or encourage the doing of an act. That express words directing
a person to commit suicide are not indispensable, and instigation may, in an
appropriate case, be inferred from a continued course of conduct. Such an
inference must however, emerge with reasonable certainty from the conduct
attributed to the accused and cannot rest merely upon the fact that the
deceased felt distressed or aggrieved by that conduct.
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79. The material must therefore disclose conduct, amounting to abetment
within Section 107 of IPC, accompanied by the requisite mens rea and a
proximate connection with the suicide. In S.S. Chheena v. Vijay Kumar
Mahajan, (2010) 12 SCC 190 , M. Mohan v. State, (2011) 3 SCC 626 and
Gurcharan Singh v. State of Punjab, (2020) 10 SCC 200 , the Apex Court
emphasised upon the necessity of there being a positive act of instigation or
intentional aid, the requisite mens rea , and a proximate relationship between
the conduct of the accused and the suicide. More recently, in Prakash v. State
of Maharashtra, (2026) 6 SCC 251 , while considering a challenge arising
from the rejection of an application for discharge, the Supreme Court
reiterated, that the record must disclose direct or indirect incitement in close
proximity to the suicide, a discernible intention to abet, and an active act of
such nature as leaves the deceased with no other option. Therefore,
harassment, matrimonial discord or a strained relationship, without the
positive and intentional contribution contemplated by Section 107 of the IPC,
does not complete the offence under Section 306 of the IPC.
80. The distinction where the deceased has left a note or a message
attributing responsibility for the suicide to another person assumes particular
significance. In Madan Mohan Singh v. State of Gujarat, (2010) 8 SCC 628 ,
the Supreme Court examined the allegations underlying such an attribution
and found, that they did not disclose the ingredients of abetment. Similarly,
in Netai Dutta v. State of W.B., (2005) 2 SCC 659 , the reference to the
accused in the suicide note was held to be insufficient in nature, where the
material did not disclose instigation or intentional aid. The principle that
therefore emerges from these aforementioned decisions, is that the deceased’s
attribution of responsibility to another person is a relevant piece of evidence,
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but it does not by itself determine, whether the person named has committed
the offence under Section 306 of IPC.
81. This requirement of there being these statutory ingredients or elements
of the offence under Section 306 IPC is not diluted by Section 113A of the
Evidence Act either. This provision i.e. Section 113A of the Evidence Act
permits, but does not compel, the Court to presume abetment, where a married
woman commits suicide within seven years of marriage and the husband or
his relative is shown to have subjected her to cruelty. Even upon disclosure of
those foundational facts, the Court must have regard to all the other
circumstances of the case before drawing such a presumption. As explained
in Gurjit Singh v. State of Punjab, (2020) 14 SCC 264 , cruelty and abetment
remain distinct legal enquiries. The existence of cruelty, even when coupled
with suicide within seven years of marriage, does not automatically establish
the offence under Section 306 of IPC.
82. The present enquiry is therefore, whether the material accompanying
the police report when taken at its face value and considered as a whole, raises
grave suspicion that Mayank Singhvi abetted the suicide, or not.
83. The first aspect that needs to be considered by this Court concerns the
sale of the deceased’s flat and the suggestion that the transaction formed part
of the financial pressure exerted upon her which eventually led to her
committing suicide. The conversation between the deceased and her mother
on 27.02.2018 gives a contemporaneous account of her reasons for selling the
property. When her mother cautioned her that, “N be very very sure that u
want to sell it” , the deceased replied that she was “Getting an excellent deal”,
that the property was old and that she was “getting 5 times” . Her mother’s
concern was that she should retain an alternative place to live to which the
deceased answered that she would not, in any event, return to that property.
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84. The deceased then explained how she proposed to use the proceeds.
“Let the money come 1st. I have a year to decide what I wanna do with it” ,
“1.45 is not a small amount. I can easily get a new 3 bedroom in Gurgaon
high rise or if I invest with Mayank it will be in my name.” She described this
as “a win win”. She further stated that, even if the new property were held
jointly, Mayank would contribute the larger share, and added, “But he wants
to buy in my name” . Her assurance to her mother was also unequivocal which
is clear from the following text that “I’m completely guarding my financial
investments” .
85. So the replies of the deceased show that she regarded the proposed sale
as being financially advantageous to her. That she was considering whether
to purchase a separate residence or invest the proceeds with Mayank, while
retaining an interest in the property to be acquired. She explained to her
mother why she wished to sell the property, the return she expected and the
safeguards she proposed. Viewed in this context, the conversation does not in
any way supports the inference, that she was being compelled to surrender
either the property or its sale proceeds.
86. The mother’s own response in this regard is also significant. During
this private discussion concerning the financial security of the deceased, she
wrote, “Financially M has been very good with u..” and “The moment he had
money he’s been spending so much on u.” The deceased replied, “Yup I know
and understand.” These contemporaneous exchanges do not in any way
indicate, that the proposed sale or investment was being forced upon the
deceased, much less that the transaction formed part of any conduct intended
to drive her to suicide. The allegation concerning this transaction, therefore,
does not furnish material sufficient to support a charge under Section 306 of
IPC.
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87. The next aspect is the deceased’s treatment for her condition and the
mother’s repeated concern that she should take her medication. On
15.05.2018, the mother informed Mayank that she would be meeting a doctor
and asked him to keep her informed about the deceased’s behaviour. She
advised him to remain patient, avoid arguments and provide affection and
support. Later that day, she informed him that medication had been advised
and that she had sent the prescription to the deceased.
88. On 16.05.2018, the deceased sent Mayank an attachment and asked him
to stop on his way from the gym and obtain the medicines. When he asked
what it was and what it was for, she informed him that her mother had gone
to the doctor for her and stated, “I told her that I think I have depression.. it’s
for that” . In the exchange between Mayank and the mother on the same date,
he informed her that the deceased had sent him the prescription and asked him
to obtain the medicine. The mother replied, “Also see she takes it regularly.
Start from Tonite.” Mayank stated that he had visited two stores where the
medicine was unavailable and that one store would deliver it the following
morning. The mother subsequently asked him to wait until she consulted
another doctor and stated, “She’s been diagnosed with mild depression.”
89. This exchange is significant for two reasons. First, the concern about
the condition of the deceased came from the deceased herself and was
constantly being expressed by the mother while the treatment was being
arranged for her. It was not an explanation that was first advanced by Mayank
as a cause of the death of the deceased. The chats between the deceased and
Nillum Batra and between Nillum and Mayank Singhvi show that the
deceased was constantly on medication for depression. It is the deceased
herself who once stated to Mayank Singhvi that her mother went to the doctor
because she i.e. the deceased thought that she is suffering from depression.
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Second, the mother sought his assistance in obtaining the medicine and
ensuring that it was taken regularly. His responses in this exchange, concerned
obtaining the prescribed medicine. This particular course of conduct supports
his participation in the arrangements for treatment and it supplies no inference
of instigation or intentional aid to the deceased to commit the alleged suicide.
90. The communications between mother and daughter show not only
repeated reminders, but also the deceased’s own statements concerning her
use of the medicines. On 20.06.2018, when her mother reminded her to take
them before sleeping, the deceased replied that she would take them and sleep
first. On 04.07.2018, in response to her mother’s query whether she had been
taking the medicines, she stated that she had not taken them the previous night
because they made it difficult for her to wake without nine to ten hours’ sleep.
On 10.07.2018, when her mother reminded her of her promise to take the
medicines regularly and asked whether she would take them that night, the
deceased replied, “Already took” . She immediately added, “Have taken them
so takes me max an hr to sleep” . Further reminders followed on 11.07.2018
and 12.07.2018. These communications go beyond the mother’s reference to
a diagnosis or her constant reminders to the deceased to begin a treatment as
they contain the deceased’s contemporaneous acknowledgments concerning
her actual use of the medicines.
91. These exchanges therefore place the deceased’s treatment and her own
reported use of medication among the circumstances preceding the incident.
Generally, suicide by a person receiving treatment for depression does not
exclude abetment of the same by another person, but if the material on record
when taken at face value shows that in the particular case concerned, there is
no prima facie material to show that the accused has abetted the suicide of the
deceased, this Court is of the opinion that it would be a travesty to send such
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person to trial on the bases of the same material. Therefore, the relevance of
the exchanges noted above is that her emotional condition had been
recognised before the incident, treatment was being pursued, and Mayank had
participated in the arrangements for obtaining the prescribed medicine. The
exchanges themselves disclose a combined effort to treat the deceased’s
condition. It also shows no act of instigation or intentional aid. His liability,
if any, must arise therefore, from conduct satisfying Section 107 IPC, and not
from the occurrence of suicide alone. And as can be seen from the discussion
made till now, no such conduct has been shown which would satisfy any
element of Section 107 IPC.
92. The record also contains a prescription dated 15.05.2018 referred to in
the aforesaid communications, as well as a handwritten clinical note,
regarding the deceased. The said documents are reproduced hereunder:
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93. The purpose of reproducing the above clinical note and prescription is
to notice the emotional and behavioural tendencies recorded in relation to the
deceased before the incident. The clinical note records depression and
sadness, worsening behaviour over the preceding five (5) months, aggression,
agitation, compulsive self-destructive behaviour, excitability, hostility, self-
harm and lack of restraint. It thus shows, that self-harm and compulsive self-
destructive behaviour had been medically noticed as features of her condition.
Read with the communications concerning her depression and treatment, this
material raises a reasonable possibility that the suicide was also connected
with her depressive condition and the self-destructive tendencies so recorded.
The occurrence of suicide cannot, therefore, by itself support an inference that
Mayank had instigated or intentionally aided its commission.
94. The allegations of violence and humiliation must next be considered on
their own terms. The email dated 23.06.2018 addressed by the deceased to her
Advocate Aman Hingorani contains the deceased’s account of the marriage
and several disputes between the spouses wherein she has alleged physical
assaults, abusive language and humiliation. She also stated, “He has led me
to depression and now he and his parents are calling me mad” . Now the case
for discharge under Section 306 of IPC cannot proceed by treating these
allegations as absent. Their substance is that Mayank’s alleged conduct had
caused her considerable suffering and had contributed to the breakdown of
their marriage. But the account of the individual incidents also explains the
setting in which these allegations arose. In describing an incident in July 2016,
the deceased stated, “He struck me again” , and then wrote, “I picked up the
glass and broke it on my head coz I just couldn’t take anymore of his abuses
and insinuations.” In another episode, she described an exchange of abusive
words, an assault upon her and her response with the phone in her hand, “after
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2 or 3 slaps I struck him with it on his head.” Now these passages describe
confrontations that escalated into violence. So the act involving the glass was
described as her response to alleged abuse, and the act involving the phone as
her response to being struck. Read in their stated context, they disclose the
course of the quarrels and the deceased’s reactions during them.
95. The mother’s message dated 09.04.2018 provides further
contemporaneous material concerning these disputes. In a message described
as “Ten Commandments” , she advised the deceased: “1-Anissia, no throwing
or breaking things.” , “2-Make a point, n leave it .. Don’t keep stretching it.” ,
“3-Don’t bring in families At All in ur fights.” The message also referred to
provoking a reaction and violence from Mayank and to the use of the word
“DIVORCE” during arguments. The mother was addressing a recurring
pattern of disputes in which arguments were prolonged, family members were
brought into the quarrels and objects were thrown or broken. Her advice was
therefore directed towards stopping that escalation.
96. Taken together, the email and this message depict a deeply troubled
marriage, with repeated arguments, anger, and allegations of physical
violence. The particular incidents were described as arising during disputes
between the spouses. The inference that these acts amounted to instigation of
suicide does not follow merely from their gravity or from the subsequent
death. Even on the deceased’s account, the episodes relied upon disclose
abusive and violent conduct during those confrontations but they do not, in
their stated circumstances, sufficiently disclose the further mental element
which is necessary as has been made clear above, to treat them as acts of
abetment.
97. The statement in the email that Mayank had led her into depression
expresses the deceased’s understanding of the effect of the marriage upon her.
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The statutory question under Section 306 IPC is whether the conduct,
amounted to instigation or intentional aid in the commission of suicide. And
when all the relevant material placed on record is considered for the purposes
of the present enquiry, this Court finds that the material concerning those
earlier disputes does not sufficiently disclose that element. The allegations
arising from the email therefore do not sustain the charge under Section 306
IPC merely because they describe conduct which caused distress or may
otherwise attract scrutiny under the law relating to matrimonial cruelty.
98. Now the material plainly discloses that, by July 2018, the marriage had
become deeply strained and separation was under active consideration. The
communications show that the deceased was consulting Advocate Aman
Hingorani regarding separation and that her mother was discussing the
necessary paperwork and the course to be adopted. On 10.07.2018, the mother
asked when she would meet the lawyer “to decide ur course of action” and
observed that living under the same roof was “fraught with danger” . She
thereafter advised the deceased to meet the lawyer “to chart out d course of
action” and to leave the relationship. These communications do not suggest
that matrimonial harmony had been restored and hey show an acute
breakdown in which legal advice and the possibility of the spouses living
separately were being actively considered. But when all of the aforesaid is
considered cumulatively, nothing on record shows that Mayank Singhvi aided
or abetted the commission of the alleged suicide by the deceased. All that it
shows is that the marriage had been constantly heading more and more
towards the possibility of proper breakdown and an eventual separation
between the parties.
99. The strongest material relied upon for this charge under Section 306
IPC is the sequence of communications on 13.07.2018. At approximately 2:56
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p.m., the deceased informed Seema Malik that Mayank had locked her up and
sought assistance, including police assistance. She subsequently stated that he
was sitting outside guarding her room. At approximately 4:12 p.m., she wrote:
“I am going to kill myself today bcoz Mayank has driven me to it. He finally
let me out but I can’t repair what he has done.” Her communication to
Advocate Aman Hingorani similarly attributed her decision to Mayank and
requested that he fight for her after her death. Now the allegation of
confinement is specific and close in time to the suicide. Even if for the
purposes of the present examination only , this allegation of confinement is
accepted as stated, the deceased’s subsequent message also records that she
had been let out. Therefore, the sequence of this entire incident describes
restraint during the dispute, its cessation and her ensuing declaration that she
would end her life. So the confinement in question might have been a source
of distress on her account and its proximity to the death also gives it
evidentiary significance, but it does not automatically establish that the
restraint was imposed to instigate or facilitate suicide of the deceased by
Mayank Singhvi. Had there been an express exhortation to such effect, the
case would have been at a position to be assessed differently, but presently as
the material exists, nothing of the kind has been brought to the attention of
this Court. The message establishes at best, that the deceased blamed Mayank
for her decision to end her life, but it does not provide a sufficient basis to
infer that, he intended to provoke her into committing suicide. Such an
intention cannot be inferred from her attribution of responsibility alone.
100. The final messages of the deceased noted above, hold Mayank
responsible for her suffering and her decision to die. This Court in no way,
doubts the anguish conveyed by those words, but for the purposes of the
present examination, the words “Mayank has driven me to it” remain an
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attribution which must be considered with the acts described in the record.
The principles in Madan Mohan Singh v. State of Gujarat (supra) and Netai
Dutta v. State of W.B. (supra) prevent that attribution from being treated as
a substitute for the ingredients of abetment. Having examined the alleged
conduct underlying the messages, this Court finds that the messages do not
carry the prosecution’s case beyond the deficiency already discussed.
101. The confrontation acknowledged in the petitioner’s own account
shortly before the final messages must be considered against that background.
According to that account, he questioned the deceased about her relationships
with certain persons. Even if the immediate sequence is taken to include
Mayank coming to her and a quarrel then happening between the spouses,
they still establish only the proximity of a further acrimonious matrimonial
confrontation. They do not, without material showing that his words or acts
were intended to goad, provoke, encourage or facilitate suicide, establish
instigation. The closeness of the confrontation to the suicide is relevant, but
the fact that the deceased reacted to it by taking her life cannot, by itself,
determine the intention with which the confrontation occurred.
102. The result remains the same when the material is considered as a
continuing course of conduct also. The allegations disclose repeated marital
conflict, abusive exchanges, violence and the deceased’s increasing distress.
Alongside them are her contemporaneous account of protecting her financial
interests, the mother’s efforts to address the conduct of both spouses during
their disputes, and the arrangements for treatment in which Mayank was asked
to participate. The inference of a course of conduct amounting to intentional
instigation cannot be drawn merely by combining every unhappy incident in
the marriage with the eventual alleged suicide. In the circumstances recorded
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here, the material does not raise grave suspicion of that distinct element of the
offence.
103. The mother’s earlier statement to Mayank that the deceased was
speaking of dying shows that her vulnerability was known to him. That
circumstance has been taken into account in assessing the later allegations
also. It does not, standing alone, convert every subsequent dispute into an act
of abetment. Nor does the deceased’s treatment establish this fact. The
conclusion rests on the absence of sufficient material concerning instigation
or intentional aid, after considering both her vulnerability and the conduct
attributed to Mayank.
104. Section 113A of the Evidence Act does not supply an automatic answer
in favour of the prosecution either. Even assuming the allegations of cruelty
only for the purpose of considering that provision, the inference of abetment
must be drawn with regard to all the circumstances. Here, the financial
allegations, the earlier disputes and the events of the last day have each been
examined, and their cumulative effect has also been considered. They disclose
the deceased’s distress and her attribution of responsibility, but do not provide
sufficient grounds to infer abetment. The permissive presumption cannot be
used to dispense with that assessment, merely because the suicide occurred
within seven years of marriage.
105. The concerned learned Trial Court treated the final message, “read
alone” , as sufficient to support the charge. This placed decisive weight upon
the deceased’s conclusion about responsibility without adequately examining
whether the conduct described in the record disclosed the actual ingredients
of Section 107 IPC or not. The error is thus, material in nature. A final
message may explain why the deceased decided to take her life, but liability
under Section 306 of IPC depends upon the acts and intention which are
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attributed to the accused person. For the reasons discussed above, the material
in the present case falls short of raising grave suspicion of abetment.
106. Before concluding, this Court also finds it necessary to notice the
scientific and medical material bearing upon the manner of the fall. The RFSL
report records ethyl alcohol measuring 298 mg per 100 ml of blood. In
IFFCO-Tokio General Insurance Co. Ltd. v. Pearl Beverages Ltd., (2021)
7 SCC 704 , the Supreme Court observed that even a concentration of 200 mg
per 100 ml would indicate heavy intoxication and referred to its effect upon
judgment, gait and motor coordination. The Medical Board in the present case
further opined that the injuries could have resulted from a fall from a height
or roof, while leaving the manner of death i.e. whether it was homicidal,
suicidal or accidental, to be determined from the complete investigative and
circumstantial material. These circumstances do not establish that the fall was
accidental, nor do they permit the communications sent shortly before the
incident to be disregarded. They do, however, show that the scientific and
medical material admits of the possibility that the deceased’s judgment and
balance were impaired and that she may have lost her balance. When this
material is considered with the site conditions, the eyewitness accounts and
the entire sequence of communications, the possibility of an accidental fall
cannot be ruled out altogether. This is an additional circumstance in the
cumulative assessment carried out above of the charge under Section 306 IPC
and is not, by itself, the basis of the conclusion reached by this Court.
107. The charge under Section 306 IPC against Mayank Singhvi therefore,
cannot be sustained. The impugned order dated 18.12.2019, insofar as it
directs framing of charge under Section 306 IPC, and the consequential charge
framed under that provision on 05.02.2020, are therefore liable to be set aside.
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Section 498A IPC
108. For the purposes of adjudicating the challenge to the charge under
Section 498A IPC, the allegations must be examined against the specific
meaning assigned to ‘cruelty’ by that provision. Explanation (a) encompasses
wilful conduct of such a nature as is likely to drive a woman to commit suicide
or to cause grave injury or danger to her life, limb or health, whether mental
or physical. Explanation (b) addresses harassment intended to coerce her, or
any person related to her, to meet an unlawful demand for property or valuable
security, as also harassment on account of the failure to meet such a demand.
The two limbs operate independently and require separate consideration.
Consequently, the conclusion reached in respect of the charge under Section
304B IPC does not, by itself, determine whether the material discloses cruelty
under Section 498A IPC or not. Conduct may fall within Explanation (a)
irrespective of any unlawful demand. Equally, the unlawful demand
contemplated by Explanation (b) is not confined to a demand constituting
dowry for the purposes of Section 304B IPC.
109. The enquiry in the present petitions must now, therefore, be directed to
whether the prosecution material, taken at face value, discloses either of these
statutory forms of cruelty. In Manju Ram Kalita v. State of Assam, (2009) 13
SCC 330 , the Supreme Court emphasised the gravity of the conduct and the
need to examine whether such conduct was continuous or persistent, or
sufficiently proximate, while distinguishing statutory cruelty from petty
matrimonial quarrels. At the stage of framing of charge, this assessment does
not entail a determination of the truth of the allegations or a meticulous
weighing of the evidence. But it does require the Court to identify the conduct
alleged and examine whether its nature, gravity and context disclose the
ingredients of the particular limb of Section 498A IPC sought to be invoked.
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It is on this basis that the allegations against the respective accused must be
considered.
Rajender Singh Singhvi and Sushma Singhvi (In-Laws)
110. Insofar as Rajender Singh Singhvi and Sushma Singhvi are concerned,
the challenge to their discharge under Section 498A IPC rests upon the same
body of allegations and material considered while examining their discharge
under Section 304B IPC. The factual foundation is common, but the statutory
enquiries are distinct. The conclusion under Section 304B IPC cannot,
therefore, be treated as being sufficient, by itself, to sustain their discharge
under Section 498A IPC. What requires consideration here is whether that
same material, assessed with reference to the ingredients of either limb of
Section 498A IPC, raises grave suspicion of the commission of that offence
by either parent-in-law.
111. The deceased’s detailed email dated 23.06.2018 contains no allegation
of a specific act of cruelty by Rajender Singh Singhvi or Sushma Singhvi. The
complaint dated 27.06.2018 likewise does not disclose any physical act,
persistent course of harassment or individual conduct attributable to either of
them of the nature contemplated by Explanation (a). The later statements refer
to dissatisfaction with the marriage, financial demands, support allegedly
extended to their son, pressure concerning the Vasant Kunj property and
threats. These are the allegations already noticed in the preceding discussion.
They have not been excluded merely because they were made subsequently,
nor has the absence of an allegation in the earlier communications been treated
as conclusive. Even when the later statements are taken at face value and read
with the remaining material, they remain substantially collective and do not
identify with sufficient particularity a proximate course of wilful conduct by
either parent-in-law answering Explanation (a), or harassment attributable to
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either of them for the purpose of enforcing an unlawful demand, or on account
of its non-fulfilment, within Explanation (b).
112. The allegation that the parents-in-law supported Mayank Singhvi
following matrimonial altercations, or failed to intervene in favour of the
deceased, cannot, without more, be equated with statutory cruelty. The
communications dated 06.07.2018 disclose the deceased’s objection to their
involvement in the matrimonial dispute, but do not particularise conduct
attributable to either parent which satisfies either explanation appended to
Section 498A IPC. The difficulty is thus not merely the absence of a
connection between the alleged conduct and a demand for dowry, which was
relevant to the enquiry under Section 304B IPC. It is the absence of
sufficiently particularised material disclosing that either parent-in-law
subjected the deceased to cruelty of the nature independently punishable
under Section 498A IPC.
113. It is in this context that the caution expressed by the Supreme Court in
Preeti Gupta v. State of Jharkhand, (2010) 7 SCC 667 , Geeta Mehrotra v.
State of U.P., (2012) 10 SCC 741 , K. Subba Rao v. State of Telangana,
(2018) 14 SCC 452 , and Kahkashan Kausar v. State of Bihar, (2022) 6 SCC
599 , against proceeding against relatives on general and omnibus allegations
assumes relevance. These decisions do not warrant the rejection of a genuine
case at the threshold, but they do require the Court to ascertain whether the
material discloses a specific prima facie role of each relative sought to be
prosecuted. The same factual allegations may fall for consideration under
more than one penal provision, but their invocation under distinct provisions
does not dispense with the need to disclose the ingredients of each offence
against the accused concerned.
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114. The learned Trial Court also found no document disclosing cruelty or
harassment by the parents-in-law and attached significance to the absence of
any allegation against them in the deceased’s detailed email. Upon
considering that circumstance together with the later statements and the
contemporaneous communications, this Court finds no reason to differ from
its assessment. Taken at its highest, the material indicates only that the
parents-in-law supported their son in his matrimonial dispute with the
deceased. It does not however, raise grave suspicion that either of them
committed an act of statutory cruelty. Their discharge under Section 498A
IPC is thus sustainable upon an independent examination of the ingredients
of that offence, and not merely as a consequence of the conclusion already
reached under Section 304B IPC.
115. Accordingly, the discharge of Rajender Singh Singhvi and Sushma
Singhvi under Section 498A read with Section 34 IPC is liable to be affirmed.
Mayank Singhvi (Husband)
116. Turning now to the charge under Section 498A IPC against Mayank
Singhvi, it is appropriate to consider Explanation (b) first, since the
allegations concerning monetary demands and the proceeds of the Vasant
Kunj property have already been examined in the context of Section 304B
IPC as well as Section 306 IPC. That discussion provides the factual setting
for the present enquiry, but does not conclude it. The absence of a dowry
nexus sufficient to attract Section 304B IPC does not, by itself, exclude
harassment falling within Explanation (b). The same material must therefore,
be examined independently again, to ascertain whether it discloses
harassment intended to coerce the deceased, or any person related to her, to
meet an unlawful demand for property or valuable security, or harassment on
account of the failure to meet such demand.
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117. As noticed above, the deceased’s contemporaneous communications
concerning the Vasant Kunj property records her freedom of choice regarding
its sale and the reinvestment of the proceeds, her intention to protect her title
and financial interests, and the proposal that the property to be acquired
should stand in her name. The surrounding communications also contain
offers to meet the rent for separate accommodation and provide financial
support, an express option that she need not sell the property, and her
statement that a substantial part of the proceeds had been utilised towards
repayment of her father’s loans. The relevance of this material to Explanation
(b) lies in what it discloses concerning the alleged demand, and its connection
with the mistreatment complained of. No contemporaneous communication
has been identified, in which Mayank Singhvi demanded that the sale
proceeds be transferred to him. or linked his treatment of the deceased to her
refusal to do so.
118. The supplementary statements concerning the alleged demand of ₹10
lakh, payments of cash, articles and requests for financial assistance have also
been considered together with the remaining prosecution material, and when
read cumulatively, they do not disclose a sufficiently specific and proximate
course of harassment directed towards enforcing an unlawful demand or
occasioned by its non-fulfilment. The deficiency is thus not merely the
absence of a marriage-related dowry demand, but the absence of the necessary
nexus between the harassment alleged by Mayank Singhvi and the coercive
purpose, or non-fulfilment, contemplated by Explanation (b). The material
therefore, does not disclose the ingredients of that limb. This conclusion now
leaves for separate consideration of this Court, as to whether the conduct
attributed to Mayank Singhvi falls within Explanation (a) appended to Section
498A IPC or not.
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119. What remains for consideration now, is whether the material against
Mayank Singhvi discloses cruelty within Explanation (a) to Section 498A
IPC. This enquiry is independent, both of the conclusion concerning unlawful
demands under Explanation (b) and of the conclusion already reached
concerning abetment under Section 306 IPC. The email dated 23.06.2018
contains allegations of assault during the honeymoon and thereafter, of
humiliation, controlling conduct and disputes during May and June 2018.
Nillum Batra’s subsequent statement also refers to an incident of violence
allegedly witnessed by her. The allegation of confinement on the day of the
incident and the deceased’s final communications have also been considered,
together with the remaining prosecution material, in examining, whether the
ingredients of Explanation (a) to Section 498A IPC are disclosed or not.
120. In State of M.P. v. Sheetla Sahai (supra) , the Supreme Court
emphasised the need to consider the entirety of that material including the
circumstances favourable to the accused. Such consideration is distinct from
accepting an independent defence version or undertaking a trial of disputed
facts, but the enquiry remains, whether the material read cumulatively,
furnishes sufficient ground to proceed for the particular offence alleged.
121. Read in its entirety, the email describes an acrimonious matrimonial
relationship involving disputes concerning intimacy, social interactions,
suspected relationships, household affairs, expenditure and intervention by
both families. Alongside the allegations of assault, it refers to retaliatory acts,
periods of resumed companionship and attempts to preserve the marriage. The
surrounding communications similarly record reciprocal conflict, apologies
concerning particular incidents, efforts to obtain professional counselling and
repeated discussions concerning reconciliation and separation. These
circumstances do not efface the allegations of violence but they do form the
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context in which the nature and course of the conduct attributed to Mayank
Singhvi must be examined.
122. The contemporaneous communications of Nillum Batra also form part
of this record. In May 2018, she commended the restraint and understanding
then shown by Mayank Singhvi and requested that she be kept informed. On
03.06.2018, she wrote to the deceased: "Even now no wrong has been done to
you. No one is against u. Mayank n we all love u, are with u nd will always
support u”. Nillum Batra subsequently explained that she had initially
believed Mayank Singhvi over her daughter, that she had been misled and that
she had thereafter witnessed violence. The earlier communications cannot be
treated as a retraction of allegations made subsequently nor can the
subsequent explanation be disregarded. Both must be considered without
conclusively determining, at this stage, the credibility of either account.
123. The references to depression, medication and treatment are similarly
relevant as part of the surrounding circumstances. They do furnish a basis to
discredit the deceased or to attribute the matrimonial discord to a medical
condition. Equally, expressions of affection, offers of financial support and
attempts at counselling do not establish that the alleged violence could not
have occurred. Now the limited relevance of all these aforementioned
communications is, that the prosecution record, contains differing
contemporaneous accounts that bear upon the nature, continuity and gravity
of the conduct alleged against the revisionist Mayank Singhvi. They must be
considered only for that purpose.
124. The final communications must also be examined in conjunction with
the earlier allegations. They convey the deceased’s perception that Mayank
Singhvi had caused irreparable harm and driven her to take the extreme step.
That attribution is relevant, but does not dispense with an examination of
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whether the conduct disclosed by the material on record, answers Explanation
(a) or not. To the extent that the learned Trial Court treated the final attribution
to Mayank Singhvi as being sufficient to establish statutory cruelty and
thereafter invoked Section 113A of the Evidence Act to infer abetment, this
reasoning did not maintain the distinction between the foundational fact and
the presumption under law. Cruelty must be independently disclosed before
the presumption under Section 113A of the Evidence Act can be considered.
This presumption cannot by itself supply the very foundation of the offence.
125. The issue is thus not whether the allegations are serious, or whether
their truth can finally be determined at this stage, but whether, the complete
prosecution material raises grave suspicion of wilful conduct of such a nature
as is likely to drive the woman to commit suicide or to cause grave injury or
danger to her life, limb or mental or physical health. That enquiry cannot be
replaced either by the existence of matrimonial discord or by the fact that the
marriage ended in an unnatural death.
126. So considered cumulatively, the record discloses a deeply distressed
matrimonial relationship, allegations and counter-allegations, harsh
exchanges, prior allegations of assault and an unresolved dispute shortly
before the fall. It also records reciprocal conflict, contemporaneous efforts at
treatment and counselling, discussions concerning separate accommodation
and property, and repeated attempts at reconciliation. Applying the distinction
between suspicion simpliciter and grave suspicion explained by the Supreme
Court in Union of India v. Prafulla Kumar Samal (supra) and Sajjan Kumar
v. CBI (supra) , and considering these circumstances together, without
treating the latter as disproving the former or the final attribution as conclusive
of statutory cruelty, this Court is of the opinion that the material does not raise
grave suspicion of the particular offence contemplated by Explanation (a).
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127. The learned Trial Court did not give due effect to the entirety of the
material accompanying the police report and treated the deceased’s final
attribution as supplying the statutory character of the conduct alleged. For the
reasons discussed above, the material, considered as a whole, gives rise to
suspicion but does not attain the degree of grave suspicion necessary to
proceed under Sections 227 and 228 CrPC. The direction to frame a charge
against Mayank Singhvi under Section 498A IPC is, therefore, liable to be set
aside.
128. The conclusions in respect of the several offences rest upon their
distinct statutory requirements. The material does not disclose the requisite
dowry nexus under Section 304B IPC against any of the accused persons. As
regards Mayank Singhvi, it does not disclose the intentional instigation or aid
necessary, to sustain a charge under Sections 107 and 306 IPC. The material
against Rajender Singh Singhvi and Sushma Singhvi does not raise grave
suspicion of either form of statutory cruelty under Section 498A IPC either.
Upon an independent consideration of both explanations to that provision, the
material against Mayank Singhvi is also insufficient to sustain the charge
under Section 498A of IPC.
129. Consequently, the discharge of Mayank Singhvi under Section 304B
read with Section 34 IPC, and of Rajender Singh Singhvi and Sushma Singhvi
under Sections 304B and 498A read with Section 34 IPC, is liable to be
affirmed. The direction to frame charges against Mayank Singhvi under
Sections 498A and 306 IPC is also liable to be set aside, and consequently, he
is liable to be discharged of those offences as well.
130. Before parting, this Court wishes to express its concern over the
tendencies today, to implicate the husband’s relatives in matrimonial
disputes through sweeping allegations of cruelty. The anguish arising from
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a troubled marriage is understandable, but it cannot justify drawing the
entire family into criminal proceedings without a specific role being
attributed to the persons concerned. A criminal prosecution has
consequences that extend beyond the courtroom, affecting reputation,
livelihood and family life. The law must therefore, afford effective
protection to a woman subjected to cruelty, while ensuring that relatives are
not made to face prosecution merely because of their relationship with the
husband, and even the husbands should not be, without cause, penalized.
131. This Court also wishes to emphasise the importance of timely support
from the parental family when a daughter speaks of violence or persistent
mistreatment in her marriage. Her concerns should not be brushed aside
with an advice to adjust, nor should a fear of social disapproval stand in the
way of offering her a safe home. A daughter’s return to her parents should
never be regarded as a matter of shame for them. Preserving a marriage
cannot take precedence over her safety and dignity, and support should not
have to await an irretrievable tragedy.
CONCLUSION
132. In view of the foregoing discussion, CRL.REV. P. 29/2020 preferred
by Nillum Batra and CRL.REV. P. 297/2022 preferred by the State are
dismissed. The impugned order dated 18.12.2019 passed by the learned
Additional Sessions Judge-02 (South), Saket Courts, New Delhi, in Sessions
Case No. 676/2018 , titled State v. Mayank Singhvi which arose out of FIR
No. 185/2018 registered at Police Station Hauz Khas, South District, Delhi is
upheld, insofar as it discharges Mayank Singhvi under Section 304B read with
Section 34 IPC and Rajender Singh Singhvi and Sushma Singhvi under
Sections 304B and 498A read with Section 34 IPC.
Signature Not Verified
Signed By:BHARTI
Signing Date:04.11.2026
12:34:26
CRL.REV. P. 29/2020 and connected matters Page 51 of 52

133. Further, CRL.REV. P. 170/2021 , preferred by revisionist Mayank
Singhvi, in view of the aforesaid findings, is allowed. The concerned
impugned order dated 18.12.2019, insofar as it directs the framing of charges
against him under Sections 498A and 306 IPC, and the consequential charges
framed on 05.02.2020, are set aside.
134. Accordingly, the revisionist Mayank Singhvi stands discharged of the
offences punishable under Sections 498A and 306 of IPC.
135. The pending applications, if any, in all the 3 revision petitions, stand
disposed of.
136. Interim order(s), if there, in any of the concerned petitions, also stand(s)
vacated.
137. A copy of this judgment be sent to the concerned learned Trial Court
as well as the concerned jail Superintendent for information and necessary
compliance.
138. This judgment be uploaded on the website forthwith .
MADHU JAIN
(JUDGE)
NOVEMBER 4, 2026/PG
Signature Not Verified
Signed By:BHARTI
Signing Date:04.11.2026
12:34:26
CRL.REV. P. 29/2020 and connected matters Page 52 of 52