The Supreme Court on Thursday granted bail to Bhopal-based dentist Dr. Abhijit Pandey, setting aside a Madhya Pradesh High Court order that had refused him relief in a case linked to the death of his wife, Dr. Richa Pandey. Hearing the appeal, the top court said the material on record, at this stage, did not justify keeping the accused in prolonged custody, especially after the charge-sheet had already been filed
Background of the Case
Dr. Abhijit Pandey and Dr. Richa Pandey met while running a dental clinic in Bhopal. After nearly one-and-a-half years of relationship, they got married on December 4, 2024, and began living together in Sky Dream Colony, Bhopal.
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On March 21, 2025, Dr. Richa was found unresponsive inside her locked room. She was rushed to hospital but declared dead. The death was initially treated as a suicide. Three days later, an FIR was registered on a complaint by the deceased’s brother, alleging that persistent mental harassment by the husband, allegedly due to an extra-marital relationship with a woman working at his clinic, drove her to take her life.
Dr. Pandey was arrested on March 25, 2025. The police later filed a charge-sheet invoking provisions of the Bharatiya Nyaya Sanhita (BNS) for abetment of suicide and other offences, along with sections of the Dowry Prohibition Act. The trial court framed charges in July 2025.
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In October 2025, the Madhya Pradesh High Court rejected his regular bail plea, citing the seriousness of the allegations. That order was challenged before the Supreme Court.
Senior advocate Vivek K. Tankha, appearing for Dr. Pandey, told the bench that the case was being unfairly escalated from suicide to murder and dowry death without solid evidence. He pointed out that the FIR and the initial statements of the deceased’s family members did not mention any demand for dowry.
“There is no material to suggest abetment, murder, or dowry death. The allegations of dowry demand appear only in later statements,” the defence argued, adding that the accused was a medical professional with no criminal background and had already spent months in custody.
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Opposing bail, the Madhya Pradesh government and the complainant’s counsel alleged that the deceased was killed by injecting Atracurium Besylate, an anaesthesia drug. They relied on post-mortem findings that noted multiple injuries on the body and statements of family members who later claimed there were demands for money.
Court’s Observations
After examining the record, the bench of Justice Prashant Kumar Mishra and Justice N.V. Anjaria noted several factors that weighed in favour of granting bail.
The court observed that the FIR initially treated the incident as a case of suicide allegedly triggered by mental harassment, not dowry demand. Even the first case diary statements of the deceased’s parents and brother did not contain allegations of dowry.
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“The allegation concerning demand of money or dowry came in the subsequent case diary statements,” the bench noted, pointing out the improvement in later versions.
On the medical evidence, the judges referred to the post-mortem and query reports, which suggested that some of the needle-related injuries could be self-inflicted. The court also took note that the deceased herself was an anaesthetist, and the alleged drug involved was commonly used in medical practice.
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Importantly, the court said there was no clear indication that any injury caused the death directly. The bench also recorded that Dr. Pandey had been in custody since March 25, 2025, and that the investigation was complete with the filing of the charge-sheet.
Decision
Allowing the appeal, the Supreme Court set aside the High Court’s October 6, 2025 order and directed that Dr. Abhijit Pandey be released on regular bail, subject to conditions imposed by the trial court.
“The appellant shall cooperate with the trial court and shall not influence the witnesses in any manner,” the bench ordered, making it clear that its observations were limited to the bail stage and would not affect the merits of the trial.
With this, the appeal was allowed, and the matter will now proceed before the trial court in accordance with law.
Case Title: Abhijit Pandey v. State of Madhya Pradesh & Anr.
Case Number: Criminal Appeal No. 446 of 2026
(arising out of SLP (Criminal) No. 16817 of 2025)
Date of Judgment: January 23, 2026
