Chhattisgarh High Court

Bail granted to in-laws in dowry death case citing parity and distinguishable role from husband.

VIJAY PURI GOSWAMI vs STATE OF CHHATTISGARH

Chhattisgarh High CourtJUDGMENT: March 25, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The applicants, Vijay Puri Goswami (father-in-law) and Abhishek Puri Goswami (brother-in-law), were arrested on 24.10.2025 in connection with the suicide of the deceased, who was the daughter-in-law of Applicant No. 1.

Source reference: para 1, 3

The deceased married the son of Applicant No. 1 on 16.01.2025 and committed suicide by hanging on 21.10.2025.

Source reference: para 2

Before her death, she uploaded a video alleging dowry harassment by the applicants and other co-accused.

Source reference: para 2

The defense contended that the deceased lived separately with her husband on the first floor and the suicide followed a trivial argument over a television remote.

Source reference: para 3

It was further argued that no prior complaints of harassment were lodged and the charge-sheet had already been filed.

Source reference: para 3
02

Issues

Whether the applicants are entitled to the grant of regular bail under Section 483 of the BNSS based on the period of incarceration, completion of the investigation, and the principle of parity.

Source reference: para 1, 6
03

Law Applied

The court applied Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS), which governs the High Court's power to grant regular bail.

Source reference: para 1

The substantive offences were registered under Section 80 of the Bharatiya Nyaya Sanhita (BNS) (relating to dowry death/matrimonial suicide) and Section 3(5) of the BNS (acts done by several persons in furtherance of common intention).

Source reference: para 1

The court also considered the judicial principle of parity, as a similarly situated co-accused had been granted relief.

Source reference: para 6
04

Reasoning

The court observed that the investigation was effectively complete as the charge-sheet had been filed before the competent court.

Source reference: para 6

It noted that the applicants had been in judicial custody since 24.10.2025 and had no prior criminal antecedents.

Source reference: para 6

The court distinguished the roles of the applicants from that of the deceased’s husband, noting they resided on different floors and the immediate trigger for the incident involved the husband.

Source reference: para 3, 6

Significant weight was given to the fact that the co-accused mother-in-law, Pushpalata Goswami, had already been granted bail by the same court in MCRC No. 2328/2026, establishing a ground for parity.

Source reference: para 6

Given that the trial was likely to take considerable time, the court found no justification for continued detention.

Source reference: para 6
05

Holding

The High Court allowed the bail application and ordered the release of the applicants on personal bonds with two local sureties each.

The holding was contingent upon several conditions: the applicants must not seek unnecessary adjournments, must remain present during all trial proceedings (specifically for framing of charges and recording of statements under Section 351 BNSS), and must comply with procedures under Sections 209 and 269 of the BNS in the event of default or misuse of liberty.

Source reference: para 7
Chhattisgarh High Court

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VIJAY PURI GOSWAMIvsSTATE OF CHHATTISGARH

Chhattisgarh High Court · March 25, 2026

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