The Supreme Court of India, in a significant ruling, cancelled the bail granted to a father-in-law and mother-in-law in a dowry death case, highlighting the importance of stricter judicial scrutiny in such matters. The Court observed that granting bail in cases with prima facie evidence of dowry demands and domestic violence could undermine public confidence in the judiciary.
The case involved the tragic death of Ms. Shahida Bano, who was found dead in her matrimonial home in January 2024, just two years after her marriage. Her body was discovered with a dupatta tied around her neck and attached to a ceiling fan. The post-mortem report indicated that she died due to forced strangulation, ruling out suicide. Based on this, a case was registered under Sections 304B (dowry death) and 498A (cruelty) of the Indian Penal Code (IPC), along with provisions of the Dowry Prohibition Act, against her husband and in-laws.
The Allahabad High Court had granted bail to the father-in-law, mother-in-law, and two sisters-in-law, citing reasons such as the absence of prior criminal records and the fact that some of the accused were women. However, the deceased’s father challenged this decision in the Supreme Court.
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Supreme Court’s Observations
A bench comprising Justices Vikram Nath and Sandeep Mehta noted that the case records revealed a pattern of dowry demands and extreme brutality inflicted on the victim. The Court emphasized that stricter judicial scrutiny is essential in cases where a young woman dies under suspicious circumstances in her matrimonial home, especially when there is evidence of persistent dowry-related harassment.
"When a young bride dies under suspicious circumstances within barely two years of marriage, the judiciary must reflect heightened vigilance and seriousness," the Court stated.
The Court also expressed concern over the High Court’s "mechanical approach" in granting bail, warning that such actions could shake public confidence in the judiciary.
"In dowry-death cases, courts must be mindful of the broader societal impact, given that the offence strikes at the very root of social justice and equality. Allowing alleged prime perpetrators of such heinous acts to remain on bail, where the evidence indicates they actively inflicted physical, as well as mental, torment, could undermine not only the fairness of the trial but also public confidence in the criminal justice system," the Court added.
The Supreme Court further observed that the father-in-law and mother-in-law had a principal role in pressuring the deceased with repeated dowry demands, which escalated from a motorcycle to a car. The Court noted that the deceased’s final moments involved intense violence, as evidenced by multiple injuries inconsistent with suicide.
"Where the facts clearly indicate direct involvement in the fatal events, courts must act with an abundance of caution. Thus, permitting the father-in-law and mother-in-law to remain at large would run counter to the ends of justice, especially when the evidence reflects a probable nexus between their persistent dowry demands, physical cruelty, and the deceased’s death," the Court stated.
Bail Cancelled for In-Laws, Relief for Sisters-in-Law
While the Supreme Court cancelled the bail granted to the father-in-law and mother-in-law, it did not interfere with the bail granted to the two sisters-in-law. The Court noted that their roles appeared less direct, and one of them had recently married, while the other was pursuing her education and working as a teacher.
However, the Court clarified that this leniency should not be seen as an exoneration of their alleged involvement in the case.
Call for Deeper Scrutiny in Dowry Death Cases
The Supreme Court emphasized the need for deeper scrutiny in dowry death cases, given the grave social concern they represent.
"It is unfortunate that in today’s society, dowry deaths remain a grave social concern, and in our opinion, the courts are duty-bound to undertake deeper scrutiny of the circumstances under which bail is granted in these cases. The social message emanating from judicial orders in such cases cannot be overstated: when a young bride dies under suspicious circumstances within barely two years of marriage, the judiciary must reflect heightened vigilance and seriousness," the Court observed.
The Court also reiterated that bail orders should not be granted mechanically, especially in cases involving serious crimes like dowry deaths.
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