Dying declaration specifically implicating in-laws in dowry harassment warrants rejection of regular bail.

The applicants, Jhumuk Lal Sahu and Jageshwari Sahu (father-in-law and mother-in-law), sought regular bail following their arrest for the death of their daughter-in-law, Bhavna Sahu

The deceased married the applicants' son on March 8, 2019

The prosecution alleged that after 2–3 years of marriage, the applicants subjected the deceased to continuous physical and mental cruelty over dowry demands (specifically a washing machine, fridge, and jewelry) and treated her like a maid

On November 2, 2025, the deceased committed suicide by self-immolation at her matrimonial home

Before succumbing to her injuries, the deceased gave a dying declaration to an Executive Magistrate and recorded a mobile video holding the applicants responsible for her distress

The applicants argued they were falsely implicated, the marriage lasted over seven years (precluding certain dowry death presumptions), and that they suffered from age-related ailments including tuberculosis and thyroid issues

Whether the applicants are entitled to the grant of regular bail under Section 483 of the Bhartiya Nagarik Suraksha Sanhita, 2023, in light of the specific allegations in the dying declaration and the gravity of the offence

regular bail under Section 483 of the Bhartiya Nagarik Suraksha Sanhita (BNSS), 2023

Sections 80(2) (dowry death/harassment) and 3(5) (common intention) of the Bharatiya Nyaya Sanhita (BNS), 2023

while considering bail, the court must weigh the nature and gravity of the accusation, the severity of the punishment, and the prima facie evidence against the accused

The Court found that a strong prima facie case existed against the applicants based on the material in the case diary

The Court specifically highlighted the weight of the dying declaration recorded by the Executive Magistrate, wherein the deceased explicitly attributed her suicide to the mental and physical harassment meted out by the applicants

Although the applicants contended that the marriage had subsisted for more than seven years and cited their medical conditions, the Court determined that the severity of the allegations regarding the unnatural death by burn injuries outweighed these factors

The Court reasoned that the specific role attributed to the applicants in compelling the deceased to take such an extreme step made it inappropriate to enlarge them on bail at this stage of the proceedings

It held that the nature of the offence and the existence of a direct dying declaration implicating the applicants disentitled them to relief

The Court directed the trial court to proceed and conclude the trial expeditiously but clarified that its observations did not constitute an opinion on the merits of the case