Facts
The applicant, Prahalad Singh, married the deceased, Manisha, on February 2, 2025
Source reference: p. 2Following allegations that the applicant manhandled her under the influence of alcohol, Manisha committed suicide by hanging within 15–20 days of returning to her matrimonial home
Source reference: p. 2Consequently, an FIR was registered at Police Station Susner for offences punishable under Sections 108 (Abetment of suicide) and 85 (Cruelty by husband or his relative) of the BNS, 2023
Source reference: p. 1-2The applicant has been in judicial custody since September 25, 2025
Source reference: p. 1A previous bail application was withdrawn with liberty to renew after the evidence of the deceased's parents was recorded; however, the trial has been delayed because the trial court has been vacant for three months
Source reference: p. 1Issues
1. Whether the applicant is entitled to the grant of regular bail under Section 483 of the BNSS, 2023, in light of the delay in trial and the nature of the witness statements
Source reference: p. 1-32. Whether there is prima facie evidence of harassment leading to suicide in close proximity to the date of the incident
Source reference: p. 2-3Law Applied
The court primarily applied Section 483 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, which governs the power of the High Court to grant bail
Source reference: p. 1It considered the statutory elements of Sections 108 and 85 of the Bharatiya Nyaya Sanhita (BNS), 2023
Source reference: p. 1-2The court also referred to the procedural requirement for recording statements under Section 183 of the BNSS
Source reference: p. 2Additionally, the court emphasized the principles of criminal jurisprudence regarding jail incarceration, the likelihood of recidivism, and the right to a timely trial, as reflected in Section 346 of the BNSS regarding the examination of witnesses
Source reference: p. 3-4Reasoning
The court observed that while there were prior allegations of discord, statements from the father and brother of the deceased recorded under Section 183 of the BNSS indicated that on the day of the incident, the deceased had called her family and stated she was "happy"
Source reference: p. 2Consequently, the court found no prima facie evidence of harassment or abetment in "close proximity" to her death
Source reference: p. 2Regarding the applicant's criminal history, the court noted that his past involvement was limited to a minor excise offence and two pending trials, neither of which suggested a significant risk of recidivism or tampering with evidence
Source reference: p. 2-3The court further reasoned that since the trial court is currently vacant and the trial would take considerable time to conclude, continued incarceration of the 25-year-old applicant was unnecessary, especially as he has family roots and property, minimizing the risk of him fleeing from justice
Source reference: p. 3Holding
The court allowed the second bail application, holding that the applicant’s contentions possessed prima facie merit and that there was no compelling reason for continued incarceration
The court ordered the applicant to be released on bail upon furnishing a personal bond of Rs. 50,000 with one surety of the same amount, subject to specific conditions including mandatory attendance at all trial hearings and a strict injunction against tampering with evidence
Source reference: p. 3-4Original Court PDF
Prahalad SinghvsThe State Of Madhya Pradesh
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