Allahabad High Court Slams Delay in Forensic Viscera Reports While Denying Bail to Husband Accused in Wife’s Dowry Death Case

By Shivam Y. • November 12, 2025

Allahabad High Court rejects bail to husband in dowry death case; slams delay in viscera reports, directs UP govt to ensure faster forensic communication. - Ramratan vs. State of Uttar Pradesh

In a strongly worded order, the Allahabad High Court on November 7, 2025, refused to grant bail to one Ramratan accused in the alleged dowry death of his wife Prem Lata. The bench of Justice Samit Gopal also expressed serious concern over procedural lapses, especially the delay in submission of viscera reports from forensic laboratories, calling it a “disturbing practice” that hampers fair investigation.

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Background

The case arose from Case Crime No. 26 of 2024 registered at Police Station Mohammadabad, District Farrukhabad. The complainant, Atal Bihari, had lodged an FIR alleging that his sister Prem Lata was tortured by her husband Ramratan and in-laws over dowry demands specifically, a motorcycle and one lakh rupees. Despite the family’s repeated efforts to reconcile, the harassment allegedly continued.

On February 4, 2024, the family was informed that Prem Lata had been admitted to a city hospital in Farrukhabad. By the time they arrived, she was in the ICU, struggling for life. Doctors declared her dead by afternoon. The postmortem report noted injuries on her face, neck, and body. Since the cause of death was uncertain, her viscera (internal organ samples) were preserved for chemical analysis.

Court's Observations

During the bail hearing, Justice Samit Gopal noted glaring lapses in the handling of the viscera report. The Court referred to a previous order issued on October 10, 2025, directing the Senior Superintendent of Police (SSP), Farrukhabad, to clarify whether the prosecution had received the report.

In compliance, the SSP submitted a personal affidavit revealing that the viscera samples had been sent to the Forensic Science Laboratory (FSL), Jhansi, in February 2024. However, despite multiple reminders in March, April, June, and August 2024, the laboratory report was only prepared in September 2024 and reached the investigating officer months later in February 2025.

“The investigation concluded without receiving the viscera report and charge-sheet was submitted,” the bench noted with displeasure. “This shows that in so far as the cause of death of the deceased was concerned, it was not conclusive… investigation was on some count incomplete.”

The Court observed that viscera reports are crucial evidence in unnatural death cases.

“It is one of the links in the chain of circumstances and should reach investigating officers in time,” the order stated.

Justice Gopal went a step further, directing the Chief Secretary, Director General of Police, and Director General of Medical Health of Uttar Pradesh to ensure that viscera reports are communicated “expeditiously without any wastage of time.”

“The bench observed, ‘There has to be a procedure and process for expeditiously transmitting viscera reports to the Investigating Agency for complete and effective assessment during investigation.’”

Arguments Before the Court

Ramratan’s counsel, Advocate Shad Khan (holding brief for Habaldar Singh Katheria), argued that his client was innocent and falsely implicated. He pointed out that it was Ramratan’s father who had admitted Prem Lata to the hospital. The defense further claimed that the deceased was short-tempered and suffered from depression due to marital distance, leading her to consume poison herself.

The lawyer also cited a 2013 circular issued by the DGP, Uttar Pradesh, mandating that charge-sheets in such cases must not be filed without viscera reports alleging that this rule was ignored in the present investigation.

The State, represented by AGA Ajay Singh, opposed the bail. He argued that since the deceased died within seven years of marriage in her matrimonial home, and viscera analysis confirmed the presence of organochloro insecticide (a poisonous chemical), the case fell squarely within the ambit of dowry death under Section 304-B IPC.

“The applicant is the husband the primary accused and his role cannot be equated with that of the co-accused,” the prosecution submitted, emphasizing that the parents-in-law had already been granted bail on separate grounds.

Court's Decision

After hearing both sides, the Court concluded that no ground for bail was made out. Justice Gopal noted that the death occurred under unnatural circumstances within seven years of marriage, following continuous allegations of dowry harassment.

Given the serious nature of the charges and the fact that viscera tests confirmed poisoning, the Court held that Ramratan's case could not be compared with that of his parents, who were already on bail.

“Looking to the facts and circumstances of the case, this Court does not find it a fit case for bail,” the order read. Accordingly, the bail application was rejected.

Before parting with the matter, the bench once again underscored the importance of timely forensic coordination and directed the Registrar (Compliance) to circulate its observations to senior state authorities for necessary action.

The case will now proceed before the trial court, where evidence is already underway.

Case Title: Ramratan vs. State of Uttar Pradesh

Case Type & Number: Criminal Misc. Bail Application No. 30824 of 2025

Date of Order: November 7, 2025

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