Facts
The applicant, the mother-in-law of the deceased (Kavita Verma), sought regular bail following her arrest on 23.09.2025.
Source reference: para. 2-3The prosecution alleged that the co-accused (husband of the deceased) abducted the minor deceased, and subsequently, the applicant and another relative harassed and taunted her for eloping.
Source reference: para. 2It is alleged that this harassment led the deceased to commit suicide by consuming poison on 30.06.2025.
Source reference: para. 2The applicant contended she was falsely implicated based on vague statements by the deceased's parents and noted the absence of a suicide note or any direct act of incitement.
Source reference: para. 3Issues
Whether the applicant is entitled to grant of regular bail under Section 483 of the Bhartiya Nagarik Suraksha Sanhita, 2023, considering the nature of allegations and the duration of her custody.
Source reference: para. 1, 6Law Applied
The Court applied the provisions of Section 483 of the Bhartiya Nagarik Suraksha Sanhita (BNSS), 2023, regarding the grant of regular bail.
Source reference: para. 1The substantive charges were under Sections 137(2) (Abduction), 107 (Abetment), 108 (Abetment of suicide), and 3(5) (Common intention) of the Bhartiya Nyaya Sanhita (BNS), 2023, alongside Section 84 of the Juvenile Justice (Care and Protection of Children) Act, 2015.
Source reference: para. 1The court relied on the principle that bail may be granted where there is a lack of direct evidence or a "suicide note" connecting the accused to the alleged instigation of suicide, especially when the investigation (charge-sheet) is complete.
Source reference: para. 3, 6Reasoning
The Court observed that the primary allegations regarding abduction and physical assault were directed at the co-accused husband, rather than the applicant.
Source reference: para. 3Regarding the charge of abetment of suicide, the Court noted the absence of any suicide note or evidence indicating an "active or direct act" by the applicant that led the deceased to take her life.
Source reference: para. 3, 6The applicant’s involvement appeared limited to oral taunts as alleged by the parents of the deceased.
Source reference: para. 3The Court further reasoned that since the charge-sheet had already been filed and the applicant had been in custody since 23.09.2025, her continued detention was unnecessary as the trial would take considerable time to conclude.
Source reference: para. 6Holding
The Court allowed the bail application and ordered the release of the applicant on a personal bond with two sureties.
The holding was based on the lack of a suicide note and the completion of the investigation.
Source reference: para. 6The release is subject to conditions, including the applicant’s mandatory presence during charge framing and statement recording under Section 351 of the BNSS, and a prohibition against seeking unnecessary adjournments.
Source reference: para. 7Original Court PDF
Atibai Verma @ Ramkumari v. State of Chhattisgarh [MCRC No. 2225 of 2026 (2026:CGHC:11451)]
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