MP HC Denies Anticipatory Bail To Man Accused Of Harassing Deceased Who Died By Suicide And Pressuring Her Family To Compromise

In brief

The question

1. Whether the applicant should be granted anticipatory bail in light of the allegations, the material collected during investigation, and the stage of investigation.

The court held

The Court answered the issue against the applicant.

It also directed

The Court dismissed the application for anticipatory bail.

01Facts

The applicant sought anticipatory bail in Crime No. 134 of 2026, registered at Police Station Sirmour, District Rewa, for an offence under Section 107 of the Bharatiya Nyaya Sanhita, 2023.

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The prosecution alleged that the applicant pressured the deceased and her family to compromise in a matter between them and harassed the deceased, who later died by suicide.

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The applicant denied the allegations and relied, among other things, on having been granted bail by the Allahabad High Court in a separate case arising from the deceased’s complaint.

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The State opposed bail, relying on allegations of pressure and harassment through video calls and on a call-detail record showing calls between the applicant and the deceased.

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02Issues

i.1. Whether the applicant should be granted anticipatory bail in light of the allegations, the material collected during investigation, and the stage of investigation.

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03Law Applied

The application was brought under Section 482 of the Bharatiya Nagarik Suraksha Sanhita, 2023/Section 438 of the Code of Criminal Procedure, 1973, seeking anticipatory bail in a case registered under Section 107 of the Bharatiya Nyaya Sanhita, 2023.

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The Court stated that anticipatory bail is not a rule but an extraordinary discretionary relief, to be exercised cautiously and on the facts and circumstances of the case, having regard to potential effects on the investigation; it relied on Srikant Upadhyay v. State of Bihar, (2024) 12 SCC 382.

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It also relied on Tusharbhai Rajnikantbhai Shah v. Kamal Dayani, (2025) 1 SCC 753, for the principle that anticipatory bail should not be granted routinely and requires circumspection.

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Provisions in the judgment · 7 · Linked ones open on LawLens

Bharatiya Nagarik Suraksha Sanhita, 2023 Section 482

Code of Criminal Procedure, 1973 Section 438

Bharatiya Nyaya Sanhita, 2023 Section 107 Section 137 Section 87 Section 64 Section 351

04Reasoning

Applying those principles, the Court considered the nature and gravity of the allegations, the role attributed to the applicant, the stage of investigation, and the case diary and CDR report.

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In view of the allegations that the applicant pressured and harassed the deceased, together with the CDR material indicating calls to her, the Court found no ground to extend the discretionary protection of anticipatory bail.

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