Sandeep @Sunny vs The State Of Nct Of Delhi
- Court
- Delhi High Court
$~
* IN THE HIGH COURT OF DELHI AT NEW DELHI
% Judgment reserved on: 26.05.2025
Judgment pronounced on: 01.06.2026
Judgment uploaded on: 02.06.2026
+ BAIL APPLN. 2011/2026 & CRL.M.A. 16594/2026
SANDEEP @ SUNNY .....Petitioner
Through: Mr. Prashant Sharma, Mr.
Sarthak Gupta , Ms Atti Tyagi,
Mr. Rohit Gupta, Advocates.
versus
THE STATE OF NCT OF DELHI .....Respondent
Through: Mr. Naresh Kumar Chahar,
APP for State.
+ BAIL APPLN. 2037/2026 & CRL.M.A. 16800/2026
PURAN CHAND .....Petitioner
Through: Mr. Prashant Sharma, Mr.
Sarthak Gupta , Ms Atti Tyagi,
Mr. Rohit Gupta, Advocates.
versus
THE STATE OF NCT OF DELHI .....Respondent
Through: Mr. Naresh Kumar Chahar,
APP for State.
+ BAIL APPLN. 2045/2026 & CRL.M.A. 16845/2026
SATWATI .....Petitioner
Through: Mr. Prashant Sharma, Mr.
Sarthak Gupta , Ms Atti Tyagi,
Mr. Rohit Gupta, Advocates.
versus
THE STATE OF NCT OF DELHI .....Respondent
BAIL APPLN. 2011/2026 & connected matters Page 1 of 25
Signature Not Verified
Digitally Signed
By:ZEENAT PRAVEEN
Signing Date:02.06.2026
17:34:14
Through: Mr. Naresh Kumar Chahar,
APP for State.
CORAM:
HON'BLE DR. JUSTICE SWARANA KANTA SHARMA
JUDGMENT
DR. SWARANA KANTA SHARMA, J
CRL.M.A. 16594/2026 in BAIL APPLN. 2011/2026 (exemption)
CRL.M.A. 16800/2026 in BAIL APPLN. 2037/2026 (exemption)
CRL.M.A. 16845/2026 in BAIL APPLN. 2045/2026 (exemption)
1. Allowed, subject to all just exceptions.
2. Applications stand disposed of.
BAIL APPLN. 2011/2026, BAIL APPLN. 2037/2026 & BAIL
APPLN. 2045/2026
3. Yet another case of a young girl having lost her life within
six months of the marriage and registration of an FIR under Section
80 of BNS ( erstwhile 304B of IPC ) has resulted in filing of the
present applications seeking anticipatory bail, filed by the
accused/applicants – who are husband, father-in-law and mother-in-
law of the deceased – in case arising out of FIR bearing no. 93/2026,
registered at Police Station Tilak Nagar, Delhi, for the commission of
offences punishable under Sections 85/80/3(5) of the Bharatiya
Nyaya Sanhita, 2023 (hereafter ‘ BNS ’). Vide this common order, all
the three applications shall be disposed of.
4. The primary common plea of the accused persons is the delay
in lodging of the FIR, as also there being no specific elaborate
allegations mentioned in the first statement given to the Executive
BAIL APPLN. 2011/2026 & connected matters Page 2 of 25
Signature Not Verified
Digitally Signed
By:ZEENAT PRAVEEN
Signing Date:02.06.2026
17:34:14
Magistrate by the complainant-father. This plea is in the background
of an undisputed fact that this statement was made by the
complainant-father to the Executive Magistrate on the same day,
when the daughter of the complainant was lying dead in the
mortuary, having died an unnatural death, within six months of
marriage. The applicants argue that this entitles them to grant of
anticipatory bail.
BRIEF FACTS
5. Briefly stated, facts of the present case are that the deceased
Heena @ Anu had got married to accused no.1/applicant Sandeep @
Sunny on 11.12.2024 in accordance with Hindu rites and ceremonies
at Dada Chodarana Mandir, Dharamshala, Pooth Kalan, Delhi. It was
alleged by the complainant, i.e. father of the deceased, that soon after
the marriage, the deceased had been subjected to cruelty, harassment
and humiliation by the accused persons on account of unlawful
demands for dowry. It was further alleged that despite the
complainant having incurred substantial expenditure and having
fulfilled the demands raised at the time of marriage, the deceased had
been continuously harassed in connection with dowry demands. The
complainant further alleged that on 02.07.2025, he had received
information from accused no.1 that the deceased had fallen from the
staircase of her matrimonial home and had been admitted to a
hospital in a critical condition. Upon reaching the hospital, the
complainant had suspected foul play and had alleged that the accused
BAIL APPLN. 2011/2026 & connected matters Page 3 of 25
Signature Not Verified
Digitally Signed
By:ZEENAT PRAVEEN
Signing Date:02.06.2026
17:34:14
persons had been giving differing versions regarding the incident.
The deceased had subsequently succumbed to her injuries on
03.07.2025 during her treatment at the hospital. During inquiry, an
MLC intimation pertaining to the deceased was received from DDU
Hospital, wherein a history of hanging at the residence had been
recorded, as informed by the husband. The crime scene had been
inspected and proceedings under Section 196 of the BNSS had been
conducted. Statements of the family members had then been recorded
by the Executive Magistrate. As per the investigating agency, no
allegations relating to dowry death had been made by the
complainant or his family members in their statements before the
Executive Magistrate and the apparent cause of death had prima facie
been found to be hanging. Thus, no FIR was registered.
6. Thereafter, pursuant to directions issued by the learned
Magistrate, the present FIR came to be registered on 13.03.2026.
SUBMISSIONS BEFORE THE COURT
7. The learned counsel appearing for the applicant Sandeep @
Sunny argues that the applicant has been falsely implicated in the
present case and has no role whatsoever in the death of the deceased.
It is submitted that on the intervening night of 01/02.07.2025, the
deceased had attempted suicide by hanging after locking herself
inside a room at the matrimonial home and that upon noticing the
incident, the applicant had immediately rushed her to Amar Leela
Hospital and thereafter shifted her to DDU Hospital for better
BAIL APPLN. 2011/2026 & connected matters Page 4 of 25
Signature Not Verified
Digitally Signed
By:ZEENAT PRAVEEN
Signing Date:02.06.2026
17:34:14
treatment, but despite all efforts, she unfortunately succumbed on
03.07.2025. It is contended that the applicant had actively
participated in her treatment, funeral and subsequent religious
ceremonies and that no allegation of dowry demand, harassment or
foul play had been made by the complainant or his family members at
that stage. It is argued that during the inquiry conducted under
Section 196 of BNSS, the statements recorded before the Executive
Magistrate did not contain any allegation regarding dowry demands
and, therefore, the subsequent allegations made by the complainant
constitute a material improvement. It is further argued that the
deceased had not been on cordial terms with her parental family, was
unwilling to continue matrimonial life and had expressed a desire to
devote herself to religious pursuits. The learned counsel further
contends that after completion of the last rites, the complainant and
his family members, in connivance with one Vansh Mathur, had
allegedly demanded a sum of ₹1 crore, later reduced to ₹50 lakhs,
from the applicant and his family members and had threatened to
falsely implicate them upon their refusal to meet the said demand. It
is submitted that the incident had taken place on 02.07.2025 and the
deceased had expired on 03.07.2025, whereas the complaint was
lodged much later i.e. 19.07.2025 and the FIR came to be registered
only pursuant to directions of the learned Magistrate, which indicates
that the allegations are an afterthought. It is also contended that no
complaint regarding dowry harassment had ever been lodged during
the lifetime of the deceased, that the parties belong to a modest
BAIL APPLN. 2011/2026 & connected matters Page 5 of 25
Signature Not Verified
Digitally Signed
By:ZEENAT PRAVEEN
Signing Date:02.06.2026
17:34:14
economic background and that the allegations are false, fabricated
and motivated. It is also submitted that the applicant has clean
antecedents, is a permanent resident of Delhi, has cooperated with the
investigation throughout and there is no likelihood of his absconding,
tampering with evidence or influencing witnesses.
8. On behalf of the applicant Puran Chand, it is argued that the
applicant has been falsely implicated merely because he is the father-
in-law of the deceased and that no specific allegations have been
levelled against him. It is argued that the deceased had attempted
suicide on her own and that the applicant had no role whatsoever in
the circumstances leading to her death. It is also stated that the
statements recorded before the Executive Magistrate immediately
after the death of deceased did not contain any allegation of dowry
demand or harassment against the applicant and that the allegations
subsequently levelled in the complaint dated 19.07.2025 are an
afterthought. The learned counsel also submits that the applicant is an
elderly person, has clean antecedents, has cooperated with the
investigation and is neither likely to abscond nor to influence
witnesses or tamper with evidence.
9. On behalf of the applicant Satwati, the learned counsel submits
that she, being the mother-in-law of the deceased, has been roped into
the present case on the basis of general and omnibus allegations
without there being any independent material to substantiate any of
the allegations or her involvement in the death of deceased. It is
BAIL APPLN. 2011/2026 & connected matters Page 6 of 25
Signature Not Verified
Digitally Signed
By:ZEENAT PRAVEEN
Signing Date:02.06.2026
17:34:14
argued that the deceased had never lodged any complaint against the
applicant during her lifetime and that the allegations relating to
dowry demand and harassment have been concocted by the
complainant. The learned counsel argues that no useful purpose
would be served by subjecting the applicant to custodial interrogation
and prays that she be granted the protection of anticipatory bail.
10. The learned APP for the State, on the other hand, opposes the
present bail applications and argues that the allegations against the
applicants are serious in nature and pertain to death of a young
married woman within a short period of her marriage, coupled with
allegations of dowry demand and harassment. It is contended that the
investigation is still at a nascent stage and custodial interrogation of
the applicants may be required for fair and effective investigation.
The learned APP also argues that grant of anticipatory bail at this
stage may adversely affect the investigation, as there exists a
possibility of the applicants tampering with evidence, and influencing
witnesses. It is thus contended that in view of the seriousness of the
allegations leveled by the complainant in the FIR, the present bail
applications be dismissed.
11. This Court has heard arguments addressed by the learned
counsel for the accused/applicants as well as the learned APP for the
State, and has perused material on record.
ANALYSIS & FINDINGS
12. At the outset, this Court notes that one of the primary
BAIL APPLN. 2011/2026 & connected matters Page 7 of 25
Signature Not Verified
Digitally Signed
By:ZEENAT PRAVEEN
Signing Date:02.06.2026
17:34:14
arguments advanced on behalf of the applicants is that the FIR in the
present case was not registered for about nine months, allegedly on
account of contradictory complaints/statements made by the family
members of the deceased, and that the applicants were never arrested
during this period, and thus, there is no requirement for their
custodial interrogation and that the present applications deserve to be
allowed.
13. Dealing with the first and primary argument and question
raised by the learned counsel for all the applicants, this Court has to
necessarily deal with a situation where deciding this argument will
also decide as to whether and can the law expect parents, standing
beside the body of their deceased daughter and struggling to
come to terms with her death, to immediately recount every
incident, every grievance and every allegation accumulated over
the months of her matrimonial life? Can a grieving parent be
expected, within hours of such a loss, to give a complete detailed
account of all the events which may have contributed to the
unfortunate death of his or her daughter? Or can the law be so fragile
that a defence founded solely upon the absence of detailed allegations
in the earliest statements is accepted without examining the
surrounding circumstances in which those statements came to be
made?
14. In the present case, what is of significance is that both the
father and the mother of the deceased, in their earliest statements
BAIL APPLN. 2011/2026 & connected matters Page 8 of 25
Signature Not Verified
Digitally Signed
By:ZEENAT PRAVEEN
Signing Date:02.06.2026
17:34:14
recorded on 03.07.2025 before the Executive Magistrate, i.e. on the
day their daughter had passed away, had clearly expressed suspicion
against the in-laws of the deceased regarding the circumstances of her
death. They had also specifically alleged that on 02.07.2025, they had
been informed by the deceased’s father-in-law that the deceased had
fallen from stairs, however, eventually they had come to know that
she had committed suicide. The deceased’s parents had thus prayed
for justice for their daughter. In this Court’s view, once the
deceased’s parents had raised suspicion against her husband and in-
laws, in a case involving the death of a young married woman within
a few months of marriage, the matter required a prompt and effective
response from the investigating agency.
15. Significantly, the statements of both parents were not ignored
by the Executive Magistrate. After recording their statements, the
Executive Magistrate had specifically directed the SHO, P.S. Tilak
Nagar, to enquire into the matter and take action as per rules. Thus,
the earliest version of the parents cannot be read as a clean chit to the
accused persons merely because detailed allegations of dowry
demand or cruelty were not articulated therein. The statements, when
read as a whole, clearly reveal that the parents entertained suspicion
regarding the role of the husband and in-laws of the deceased in the
death of their daughter and sought intervention of the authorities.
Once such suspicion was brought to the notice of the SHO concerned
and the matter was forwarded for inquiry and action, the
responsibility shifted to the investigating agency to conduct a
BAIL APPLN. 2011/2026 & connected matters Page 9 of 25
Signature Not Verified
Digitally Signed
By:ZEENAT PRAVEEN
Signing Date:02.06.2026
17:34:14
meaningful investigation in accordance with law, moreso, since the
deceased had died in unnatural circumstances, within less than seven
months of the marriage.
16. However , the record reveals that despite the aforesaid
direction, no FIR came to be registered in the present case. The
investigating agency appears to have proceeded on the premise that
since the parents had not clearly narrated allegations of dowry
harassment in their statements before the Executive Magistrate, no
further action was warranted.
17. Faced with such inaction , the father of the deceased
submitted a detailed written complaint dated 19.07.2025. The
complaint, significantly, was made within a short period of about two
weeks from the date of death of his daughter. In the said complaint,
the father elaborated upon the allegations which, according to him,
had been narrated by the deceased during her matrimonial life,
including alleged demands for dowry, acts of harassment, physical
and mental cruelty, demands for money and other articles, and the
circumstances which led him to suspect that the death of his daughter
was not a mere accident. At this stage, the complaint dated
19.07.2025 appears to be a continuation and elaboration of the
grievance already expressed by the deceased’s family before the
Executive Magistrate, rather than an entirely new story conceived at a
later stage.
18. What is even more concerning is that despite receipt of the
BAIL APPLN. 2011/2026 & connected matters Page 10 of 25
Signature Not Verified
Digitally Signed
By:ZEENAT PRAVEEN
Signing Date:02.06.2026
17:34:14
detailed complaint dated 19.07.2025, the investigating agency still
did not register an FIR or undertake any effective investigation into
the allegations made therein. The complainant thereafter was
compelled to invoke the jurisdiction of the concerned Magistrate,
being aggrieved by non-registration of FIR, and it was only pursuant
to directions issued by the learned Magistrate under Section 175(4) of
BNSS, that the present FIR ultimately came to be registered on
13.03.2026, i.e. more than eight months after the death of the
deceased.
19. In view thereof, at this stage, therefore, this Court is unable to
accept the submission made on behalf of the applicants, that the
allegations made in the complaint dated 19.07.2025 deserve to be
discarded merely because the same were not narrated by the
deceased’s family in detail in their statements recorded on
03.07.2025 before the Executive Magistrate. While observing so, this
Court cannot ignore the fact that the FIR came to be registered only
after judicial intervention. The delay in registration of the FIR, as
noticed above, cannot be attributed only to the complainant. Rather,
the record reflects that despite the direction issued by the Executive
Magistrate to inquire into the matter and despite the complaint dated
19.07.2025 lodged by the deceased’s father, the matter remained at
the stage of inquiry for several months with the concerned Police
Station. Therefore, the applicants cannot derive any advantage from
the delay in registration of the FIR when the material on record
suggests that the complainant had been pursuing his grievance from
BAIL APPLN. 2011/2026 & connected matters Page 11 of 25
Signature Not Verified
Digitally Signed
By:ZEENAT PRAVEEN
Signing Date:02.06.2026
17:34:14
the inception. The evidentiary value and veracity of the allegations
are matters to be tested during investigation and during trial.
However, the chronology of events prima facie indicates that the
earlier statements recorded before the Executive Magistrate cannot be
viewed in isolation from the detailed complaint lodged by the
deceased’s father two weeks later, and the admitted inaction of the
investigating agency which followed.
20. Now to deal with the merits of the case , and the allegations
against the present accused/applicants, a perusal of the complaint
dated 19.07.2025 shows that the complainant has levelled detailed
allegations against the husband as well as the in-laws of the deceased.
It has been alleged that after the marriage dated 11.12.2024, the
deceased was continuously subjected to harassment, humiliation and
cruelty on account of dowry demands. The complainant has alleged
that despite having incurred substantial expenditure on the marriage,
to the tune of ₹7 lakhs and having fulfilled various demands of the
accused persons, the deceased was repeatedly taunted for bringing
inadequate dowry and was pressurised to procure further articles and
money from her parental family. It was alleged that the deceased’s
mother-in-law used to instigate other family members to harass and
beat the deceased in order to compel her to bring more dowry and on
her instigation, the deceased had been beaten on several occasions by
her husband, father-in-law and brother-in-law. It was also alleged that
the husband and mother-in-law of the deceased had even forbidden
the deceased from calling her parents, until they gave more dowry
BAIL APPLN. 2011/2026 & connected matters Page 12 of 25
Signature Not Verified
Digitally Signed
By:ZEENAT PRAVEEN
Signing Date:02.06.2026
17:34:14
and fulfilled their demands. Specific allegations have been made
regarding a demand for a heavier gold chain, as the applicant
Sandeep had allegedly returned the gold chain weighing 1 tola which
was given to him at the time of marriage and the complainant had
then replaced it with a chain weighing 1.5 tolas . The complaint
further alleges that on one occasion, the deceased was sent back to
her parental home and was asked not to return until she brings an air-
conditioner, due to which the complainant was left with no other
option but to fulfil the said demand. Further, on one occasion, father-
in-law of the deceased had allegedly asked her to bring ₹3.5 lakhs for
constructions of a separate floor on the premises. It has also been
alleged that in or around February, 2025, the deceased was compelled
to sign divorce papers and was threatened with adverse consequences
in case she declined to do so, since they had been approached by
other persons who were willing to get their daughters married to the
accused Sandeep and willing to give higher amount of dowry. It is
also specifically alleged that the accused Sandeep had even slapped
the deceased and threatened to kill her if she did not sign the divorce
papers. The complainant has further alleged that the deceased had
repeatedly informed her parental family regarding the physical and
mental harassment being meted out to her by her husband and in-
laws. The complaint attributes specific roles to the husband and in-
laws of the deceased and alleges that the continuous acts of cruelty
and dowry-related harassment ultimately culminated in the death of
the deceased on 02.07.2025. At this stage, this Court prima facie is of
BAIL APPLN. 2011/2026 & connected matters Page 13 of 25
Signature Not Verified
Digitally Signed
By:ZEENAT PRAVEEN
Signing Date:02.06.2026
17:34:14
the view that the complaint contains specific and serious allegations
of demand of dowry and harassment against the present
accused/applicants.
21. As far as the role of the applicant Sandeep @ Sunny is
concerned, there are detailed and specific allegations against him. It
has been alleged that he, being the husband of the deceased, had
subjected her to continuous mental and physical cruelty on account of
dowry demands and had repeatedly pressured her to bring money and
other articles from her parental home. The complaint attributes a
central role to him in the alleged acts of harassment suffered by the
deceased and further alleges that he had threatened, humiliated and
ill-treated her on various occasions during the short span of their
matrimonial life. There are also specific allegations that he had
supported and participated in the demands allegedly raised by other
family members, physically assaulted the deceased, and had also
compelled the deceased to sign divorce papers in or around February,
2025 and had also slapped her and threatened her with dire
consequences.
22. As far as the role of the applicant Puran Chand (father-in-
law of deceased) is concerned, this Court notes that he is not a distant
relative, who has been implicated merely on account of his
relationship with the principal accused. Rather, the complaint dated
19.07.2025 contains specific allegations against him. It has been
alleged that he had actively participated in raising dowry demands
BAIL APPLN. 2011/2026 & connected matters Page 14 of 25
Signature Not Verified
Digitally Signed
By:ZEENAT PRAVEEN
Signing Date:02.06.2026
17:34:14
and had subjected the deceased to harassment in connection
therewith, including physical cruelty. The complainant has also
specifically alleged that Puran Chand had demanded a sum of ₹3.5
lakhs for construction of a separate floor in the house and had
pressurised the deceased and her parental family in this regard. At
this stage, the Court is not required to examine the truthfulness of the
allegations, however, the allegations against the applicant are specific
in nature.
23. As far as the role of the applicant Satwati (mother-in-law of
deceased) is concerned, this Court notes that the complaint also
attributes a specific role to her in the alleged acts of cruelty and
harassment suffered by the deceased during her matrimonial life. The
complaint alleges that she had repeatedly taunted the deceased
regarding the insufficiency and quality of dowry articles brought by
her and had actively participated in pressurising the deceased and her
family to fulfil further demands. She also allegedly used to instigate
other family members to harass and beat the deceased so that she was
compelled to bring more dowry. There are further allegations against
her that she used to forbid the complainant from talking to her parents
and other family members till they complied with their demands of
dowry. Thus, the allegations against her relate to her alleged conduct
towards the deceased during the brief period of matrimonial life
preceding her death. Considering that the death of the deceased
occurred within a few months of marriage and the allegations form
part of the same chain of events which is presently under
BAIL APPLN. 2011/2026 & connected matters Page 15 of 25
Signature Not Verified
Digitally Signed
By:ZEENAT PRAVEEN
Signing Date:02.06.2026
17:34:14
investigation, this Court is of the opinion that the role attributed to
the applicant Satwati also requires a thorough investigation.
24. While examining the present applications, this Court is
required to confine itself to the assessment of the material available
on record. The deceased was admittedly married to the applicant on
11.12.2024 and died on 02.07.2025, i.e., within a period of less than
seven months of the marriage. The complaint dated 19.07.2025
contains specific allegations of dowry demands, harassment and
cruelty allegedly meted out to the deceased by the applicant and his
family members. The allegations are neither vague nor omnibus in
nature. Various specific instances have been mentioned and incidents
narrated in the complaint which, according to the complainant, were
disclosed by the deceased during her matrimonial life. At this stage,
when the accused persons have not joined investigation and NBWs
stand issued against them, the allegations cannot be brushed aside as
inherently improbable.
25. While considering an application for grant of anticipatory bail,
the Court is required to examine the nature and gravity of the
accusations, the surrounding circumstances, the stage of investigation
and the necessity of custodial interrogation of the accused persons.
26. Further, the defence sought to be projected by the applicants,
that the complainant had demanded money from the accused persons
after the death of their daughter and had got the FIR registered when
they had refused to meet his demands, this Court is of the view that
BAIL APPLN. 2011/2026 & connected matters Page 16 of 25
Signature Not Verified
Digitally Signed
By:ZEENAT PRAVEEN
Signing Date:02.06.2026
17:34:14
even before performing the last rites of their daughter they had
already in their first statement to the Executive Magistrate mentioned
that the accused persons are responsible for their daughter’s death
and he had pleaded for justice for himself and his dead daughter. This
coupled with the fact that a detailed complaint was lodged by the
complainant father sixteen days after the death of his daughter, which
leveled serious and specific allegations, the plea of the applicants is
found meritless and rejected at this stage.
27. Another aspect which cannot be ignored while deciding the
present bail application is the fact that a helpless father was unable to
get even the FIR registered regarding the death of his daughter within
almost six months of the marriage. The system took almost nine
months to register an FIR, resulting in plea by the applicants to grant
bail due to such delay. However, the cry for justice and the obligation
of law to do justice cannot be sacrificed at the altar of the delay
caused by the investigating system.
28. Further, this Court is shocked that despite the crime scene
having been inspected on the day the unfortunate incident of
deceased having died, broken bangles and pieces of anklets of the
deceased were found scattered on the floor. Despite this, it is
shocking that the Police did not even then, deem it appropriate to
conclude that the case needed probe and registration of the FIR.
Resultantly, the accused persons were not arrested and investigation
is still to be carried out after the accused persons joined investigation,
BAIL APPLN. 2011/2026 & connected matters Page 17 of 25
Signature Not Verified
Digitally Signed
By:ZEENAT PRAVEEN
Signing Date:02.06.2026
17:34:14
which they have not till date.
29. Thus the investigation is still at a nascent stage. The status
report itself indicates that various aspects of the matter are yet to be
investigated. This Court finds substance in the submission of the
learned APP for the State that a fair and effective investigation would
require the investigating agency to examine the allegations regarding
dowry demands, the circumstances preceding the death of the
deceased, the conduct of the parties, the electronic evidence, and
other material which may have a bearing on the truthfulness of the
rival versions. At this stage, thus, the custodial interrogation of the
applicants cannot be said to be unwarranted.
30. This Court is therefore of the considered opinion that the
allegations in the present case pertain to the death of a young married
woman within a few months of marriage and involve serious
accusations of cruelty and dowry-related harassment. The gravity of
the allegations, the stage of investigation and the overall facts and
circumstances of the case do not persuade this Court to exercise its
discretionary jurisdiction in favour of the applicants to grant them
anticipatory bail.
31. In view of the foregoing discussion , this Court is of the
opinion that the applicants have failed to make out a case for grant
of the extraordinary relief of anticipatory bail.
32. The applications of all the applicants stand rejected.
BAIL APPLN. 2011/2026 & connected matters Page 18 of 25
Signature Not Verified
Digitally Signed
By:ZEENAT PRAVEEN
Signing Date:02.06.2026
17:34:14
BEFORE PARTING WITH THE CASE
33. Though arguments are raised and questions are asked
frequently regarding the misuse of law, this is one such case
where the Court has to rather question as to why machinery of
law was not used and set into motion, where it was so required .
The evidence once lost in such cases where an innocent life already
stood lost, is difficult to compensate by even orders as the present
one and words of sympathy by the system.
34. Before parting with the present case , this Court is
constrained, in view of the peculiar facts and circumstances brought
before it, including the grievances voiced by the complainant-father
who appeared before this Court during the hearing of the present bail
applications, to take note of the apparent insensitivity displayed in
dealing with the unnatural death by hanging of a young woman aged
about 25 years, within barely a few months of her marriage. These
observations are not being made by this Court, merely to add
length to this order , but to send a clear message to those in the
system, who show such insensitivity to such incidents, that the justice
system will not show leniency to them.
Should the bereaved parents of a married daughter who dies
unnatural death within a few months of marriage be denied, even
the time to grieve?
35. A noteworthy aspect which is disturbing in this case is that the
complainant-father was informed by the family of the deceased on
BAIL APPLN. 2011/2026 & connected matters Page 19 of 25
Signature Not Verified
Digitally Signed
By:ZEENAT PRAVEEN
Signing Date:02.06.2026
17:34:14
02.07.2025 that she had fallen from the staircase and had called them
to the matrimonial home. However, upon reaching DDU Hospital,
they had come to know that the deceased had not fallen from the
staircase, but rather, to their shock, committed suicide by hanging.
She was unfit for statement and had died within a few hours of being
taken to the Hospital. It would be natural that the parents of the
deceased would have been under immense shock to have realized that
their daughter, whom they had married a few months back, had
hanged herself and was no more, while they were cognizant of the
fact that she was being harassed for bringing insufficient dowry and
specific incidents of demand of dowry etc., which the deceased had
narrated to them, while she was alive.
36. Nevertheless, neither the law nor the courts can be so
insensitive as to deny bereaved parents, even the time and space
to grieve over the untimely death of their daughter, before
expecting them to narrate every allegation with precision and
completeness.
37. The present case brings forth the story of a grieving father
who, on the very day of losing his young daughter, was expected to
recount before the Executive Magistrate, every instance, of alleged
cruelty, every demand for dowry, every humiliation suffered by his
daughter in her matrimonial home, and every circumstance which,
according to him, had led to her untimely death. This Court believes
that such an expectation is detached from the realities of human
BAIL APPLN. 2011/2026 & connected matters Page 20 of 25
Signature Not Verified
Digitally Signed
By:ZEENAT PRAVEEN
Signing Date:02.06.2026
17:34:14
conduct, in the circumstances as in the present case. A father who had
just witnessed the death of his young daughter, whose body was still
lying in the mortuary, and whom he had married off only a few
months earlier, cannot reasonably be expected to narrate, with
precision and completeness, the entire history of her matrimonial life
while still reeling under the shock of her loss. The law cannot
demand from a bereaved parent, in the immediate aftermath of such a
tragedy, the composure of a trained investigator or the recollection of
a meticulously prepared complainant.
When the time taken for registration of FIR was longer than the
duration of marriage itself.
38. As also noted in the preceding discussion, the deceased was
married on 11.12.2024 and allegedly committed suicide on
02.07.2025, i.e. within less than seven months of her marriage.
However, the present FIR came to be registered only on 13.03.2026,
pursuant to directions issued by the learned Magistrate, i.e. more than
eight months after her death. Thus, the registration of the FIR in
relation to the unnatural death of a young woman took more time
than the entire duration of her marriage itself .
39. In the opinion of this Court, the consequences of such delay in
lodging the FIR cannot be lightly brushed aside. Cases involving the
unnatural death of a young married woman clearly demand prompt
and diligent investigation by the police authorities. Every passing day
carries the possibility of loss or disappearance of evidence, fading of
BAIL APPLN. 2011/2026 & connected matters Page 21 of 25
Signature Not Verified
Digitally Signed
By:ZEENAT PRAVEEN
Signing Date:02.06.2026
17:34:14
witnesses’ memory and erosion of other evidentiary material that
may assist in discovering the truth.
40. The purpose of an investigation is to uncover the truth. It is not
expected of grieving parents to present a complete and structured
prosecution case within hours of suffering an irreparable loss of their
daughter, raised by them with love and married in the accused family.
Therefore, what is difficult to understand is that the parents of the
deceased had already expressed their suspicion against the
matrimonial family before the Executive Magistrate on 03.07.2025
itself. The Executive Magistrate, after recording their statements, had
directed the SHO to enquire into the matter and take action as per
rules. Thereafter, when a detailed written complaint was submitted on
19.07.2025 containing specific allegations, the matter still did not
culminate in registration of an FIR. The record, therefore, prima facie
reflects that despite the matter having been brought to the notice of
the authorities at the earliest point of time, the criminal law was not
set in motion.
41. The proceedings before the learned Magistrate, under Section
175(3)/(4) of BNSS further reveal the manner in which the complaint
remained pending. In the order dated 28.02.2026, the learned
Magistrate records that the Inquiry Officer had filed an Action Taken
Report (ATR) along with the statements of the complainant and his
wife recorded before the Executive Magistrate. The learned
Magistrate also records that the concerned DCP had filed a reply
BAIL APPLN. 2011/2026 & connected matters Page 22 of 25
Signature Not Verified
Digitally Signed
By:ZEENAT PRAVEEN
Signing Date:02.06.2026
17:34:14
before the Court stating that disciplinary action had been initiated
against the SHO, P.S. Tilak Nagar. The order further notes that
although the Executive Magistrate had directed inquiry into the
matter on 03.07.2025 itself, no conclusive ATR had been filed
despite sufficient time having been granted. It was in these
circumstances that the learned Magistrate directed that the ATR be
filed under the supervision of the concerned DCP.
42. This Court also finds it significant that even the learned
Magistrate, while considering the material placed before him, noticed
that the parents had been informed about the incident in the early
hours of 02.07.2025, that the deceased had subsequently succumbed
during treatment, and that the Executive Magistrate had directed
inquiry into the matter. Yet, despite the passage of several months,
the inquiry had not reached any logical conclusion. Eventually, vide
order dated 06.03.2026, the learned Magistrate observed that,
according to the complainant, the deceased had committed suicide
within one year of her marriage and had been subjected to cruelty
prior thereto. Upon perusal of the complaint and the material on
record, the learned Magistrate formed a prima facie opinion that the
facts disclosed commission of a cognizable offence and accordingly
directed registration of the FIR under the relevant provisions of law.
It is therefore evident that the FIR came to be registered only after a
judicial order directing the police to do so.
43. This Court is also of the view that the learned Magistrate was
BAIL APPLN. 2011/2026 & connected matters Page 23 of 25
Signature Not Verified
Digitally Signed
By:ZEENAT PRAVEEN
Signing Date:02.06.2026
17:34:14
conscious of the serious consequences that may follow from delay in
registration of an FIR in a case of this nature and had, therefore,
taken appropriate steps, including calling for reports and issuing
directions to the concerned DCP. However, it is also a matter of
record that the application filed by the father of the deceased seeking
registration of FIR remained pending for a considerable period of
time before the learned Magistrate.
44. This Court hopes that , in future, applications seeking
directions for registration of FIR, concerning the unnatural death of
a young woman within a short period of marriage, particularly where
allegations of dowry-related harassment are raised and the police fail
to register an FIR, shall be taken up with greater urgency by the
Courts and be listed on shorter dates so that the issue of
registration of FIR and commencement of investigation is not left
unresolved for months together .
45. This Court also sincerely hopes that the investigation, which
has now finally been set into motion, reaches its logical conclusion
uninfluenced by the omissions and commissions that appear to have
marked its initial stages. The record further reveals that the concerned
DCP had informed the learned Magistrate that disciplinary
proceedings had been initiated against the erring police officials so
that accountability, wherever required, is duly fixed.
A Parent’s Loss, and the Search for Truth
46. In this Court’s opinion, the parents of the deceased did what
BAIL APPLN. 2011/2026 & connected matters Page 24 of 25
Signature Not Verified
Digitally Signed
By:ZEENAT PRAVEEN
Signing Date:02.06.2026
17:34:14
any ordinary citizen would be expected to do. They approached the
authorities, made statements before the Executive Magistrate and
subsequently submitted a detailed complaint to the concerned SHO.
But they were ultimately compelled to pursue remedies before the
Court for registration of an FIR. The record itself reflects that the
learned Magistrate found it necessary to repeatedly seek explanations
regarding the manner in which the matter had been handled, and the
concerned DCP informed the Court that disciplinary proceedings had
been initiated against the erring police officials.
47. The unfortunate reality , however, is that the father of the
deceased was made to run from pillar to post only to ensure that an
FIR is registered and investigation is conducted regarding the
unnatural death of his young daughter.
48. For the reasons mentioned in the above discussion, this Court
dismisses the above bail applications preferred by the
accused/applicants. Pending applications also stand disposed of.
49. It is, however, clarified that nothing expressed hereinabove
shall tantamount to an expression on the merits of the case.
50. The judgment be uploaded on the website forthwith.
DR. SWARANA KANTA SHARMA, J
JUNE 01, 2026/vc
T.S./T.D.
BAIL APPLN. 2011/2026 & connected matters Page 25 of 25
Signature Not Verified
Digitally Signed
By:ZEENAT PRAVEEN
Signing Date:02.06.2026
17:34:14