Medical evidence of natural death warrants bail despite allegations of forceful religious conversion.

The appellant and the deceased, Khushbu, were in a live-in relationship since 2022

On November 9, 2025, Khushbu collapsed and died during a return journey from Ujjain

A post-mortem revealed the cause of death was shock and hemorrhage due to a ruptured ectopic pregnancy, which the appellant argued was not attributable to his actions

Following her death, the deceased’s sister filed a complaint alleging that the appellant had concealed his religious identity (using the name Rahul), manhandled the deceased, and pressured her for religious conversion

Consequently, an FIR was registered under Sections 115(2), 296(A), and 351(2) of the Bharatiya Nyaya Sanhita (BNS), 2023; Sections 3/5 of the M.P. Dharmik Swatantra Adhiniyam, 2021; and Section 3(2)(va) of the SC/ST (Prevention of Atrocities) Act

The appellant, in custody since November 12, 2025, challenged the trial court’s order dated February 14, 2026, which rejected his bail application under Section 483 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023

1. Whether the Special Judge erred in rejecting the appellant’s bail application given the medical findings and the timing of the allegations

2. Whether the appellant is entitled to bail under Section 14-A(2) of the SC/ST Act considering the completion of the investigation and lack of criminal conviction

Section 14-A(2) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989, regarding appeals against bail orders

Section 483 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, which governs bail provisions

Penal provisions under Sections 115(2), 296(A), and 351(2) of the BNS 2023

Sections 3/5 of the M.P. Dharmik Swatantra Adhiniyam, 2021

The principle that bail should be considered based on the prima facie merit of the defense, the likelihood of recidivism, and the completion of the investigation

The Court noted that the medical evidence (ectopic pregnancy) suggested the death was not caused by the appellant’s overt acts

It observed that no complaints were lodged by the deceased or her family during her lifetime regarding harassment or forceful conversion, lending weight to the appellant's contention that the allegations were potentially a reaction to her untimely death

The Court found that since the final report had been submitted, the risk of tampering with evidence was minimal

Furthermore, while the State pointed to three criminal antecedents, the Court noted the appellant had been acquitted in one and the others were pending, with no history of conviction

Given the appellant's socio-economic status and the expected duration of the trial, the Court determined there was no compelling reason for continued incarceration

The Court held that the appellant was entitled to bail as the contentions regarding his lack of complicity possessed prima facie merit and he was not a flight risk

The appellant was ordered to be released on bail upon furnishing a personal bond of Rs. 50,000 with one solvent surety, subject to conditions including regular court attendance, refraining from committing similar offences, and not tampering with evidence or witnesses