Madhya Pradesh High Court

Anticipatory bail granted to elderly relative where custodial interrogation is unnecessary for investigating alleged abetment of suicide.

Najma Bee vs The State Of Madhya Pradesh

Madhya Pradesh High CourtJUDGMENT: April 08, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The applicant, a 65-year-old woman and mother-in-law of the deceased (Yasmin Bee), sought anticipatory bail following the registration of Crime No. 146/2026 at Police Station Dindayal Nagar, Ratlam.

Source reference: p. 1

Yasmin Bee committed suicide by hanging on the night of February 18-19, 2026.

Source reference: p. 2

Allegations were made by the deceased’s relatives that the applicant taunted and harassed the deceased over her husband Irshad’s alcoholism and outstanding group loans.

Source reference: p. 2-3

The applicant contended she was falsely implicated, lived in separate accommodation, had no criminal record, and was currently undergoing the Iddat period following her husband’s death.

Source reference: p. 2
02

Issues

Whether the applicant is entitled to the grant of anticipatory bail under Section 482 of the Bharatiya Nagarik Suraksha Sanhita, 2023, considering the nature of the accusations and her personal circumstances.

Source reference: p. 1, 4
03

Law Applied

The court applied Section 482 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, regarding the discretionary power to grant anticipatory bail.

Source reference: p. 1

The substantive offences alleged were under Section 108 (Abetment of suicide) and Section 3(5) (Acts done by several persons in furtherance of common intention) of the Bharatiya Nyaya Sanhita (BNS), 2023.

Source reference: p. 1, 3

The court also relied on established bail principles concerning the necessity of custodial interrogation, the absence of criminal antecedents, and the socio-economic status of the accused.

Source reference: p. 3-4
04

Reasoning

The court examined the case diary and witness statements (Imran Shah, Razia Bi, and Amrin Bi), which prima facie suggested that the deceased’s frustration was primarily rooted in her husband’s alcoholism, his physical abuse, and the pressure of unpaid group loans.

Source reference: p. 3

The court found substance in the applicant's argument that she lived separately and was being implicated due to family frustrations.

Source reference: p. 3

It noted the applicant’s advanced age, her status as a homemaker, and her lack of prior criminal history.

Source reference: p. 3

The court determined that custodial interrogation was unnecessary for the investigation and that there was no evidence suggesting the applicant would flee from justice or tamper with witnesses.

Source reference: p. 3

It concluded that incarceration would cause undue hardship and social humiliation without benefiting the investigation.

Source reference: p. 4
05

Holding

The court allowed the application and granted anticipatory bail to the applicant.

It directed that in the event of arrest, the applicant shall be released upon furnishing a personal bond of Rs. 50,000 with one solvent surety of the same amount.

Source reference: p. 4

The holding was made subject to conditions: the applicant must cooperate with the investigation, refrain from committing further offences, and not influence or threaten witnesses.

Source reference: p. 4

The order remains effective until the conclusion of the trial unless bail is cancelled due to a breach of conditions.

Source reference: p. 4
Madhya Pradesh High Court

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Najma BeevsThe State Of Madhya Pradesh

Madhya Pradesh High Court · April 08, 2026

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