Supreme Court Cancels Bail of In-Laws in Dowry Death Case: Shabeen Ahmad vs. State of Uttar Pradesh (2025 INSC 307)

Date of the Judgment: March 03, 2025
Citation: 2025 INSC 307
Judges: Vikram Nath, J., Sandeep Mehta, J.

Can the High Court grant bail in a dowry death case based on superficial parameters? The Supreme Court, in Shabeen Ahmad vs. State of Uttar Pradesh, addressed this critical question. The court overturned the Allahabad High Court’s decision to grant bail to the father-in-law and mother-in-law in a dowry death case, emphasizing the need for stricter judicial scrutiny in such matters. The judgment was delivered by a bench comprising Justice Vikram Nath and Justice Sandeep Mehta.

Case Background

The case originated from FIR No. 0032/2024, registered at Police Station Kotwali Nagar, District Sultanpur, Uttar Pradesh. The FIR was lodged on January 23, 2024, by Shabeen Ahmad, the brother of the deceased, Ms. Shahida Bano. Shahida was married to Sami Khan on February 7, 2022. Shortly after the marriage, her in-laws allegedly began demanding additional dowry.

According to the FIR, the in-laws initially demanded a “Bullet” motorcycle, which the complainant provided. Later, they demanded a car, but the complainant couldn’t fulfill this demand immediately. As a result, Shahida was subjected to continuous harassment and cruelty by her in-laws and her husband, who was residing abroad.

On January 22, 2024, the complainant’s father received a phone call from the father-in-law, Mukhtar Ahmad, urging him to come immediately. Upon arriving at the matrimonial home, the family found Shahida’s body with a dupatta around her neck, tied to the ceiling fan. Her knees were still resting on the bed.

A post-mortem examination conducted on January 23, 2024, revealed multiple ante-mortem injuries, including traumatic contusions on the head and neck, and a prominent ligature mark around the neck. The cause of death was recorded as “Asphyxia due to ante-mortem strangulation,” indicating forced strangulation and ruling out suicide.

Timeline

Course of Proceedings

The Sessions Judge rejected the bail applications filed by the accused, noting the gravity of the offense, the unnatural death within seven years of marriage, and the specific allegations of dowry-related cruelty.

Aggrieved by the Sessions Court’s denial of bail, Accused Nos. 2, 3, 4, and 5 approached the High Court of Judicature at Allahabad (Lucknow Bench). The High Court granted bail to the respondents, citing factors such as the accused having no prior criminal history, some of them being women, and the fact that certain co-accused had already been granted bail.

Legal Framework

The case involves the following legal provisions:

✓ Section 498A of the Indian Penal Code (IPC): “Husband or relative of husband of a woman subjecting her to cruelty.” This section deals with cruelty to a woman by her husband or any relative of her husband.
✓ Section 304B of the IPC: “Dowry death.” This section addresses cases where the death of a woman is caused by burns or bodily injury or occurs otherwise than under normal circumstances within seven years of her marriage, and it is shown that soon before her death she was subjected to cruelty or harassment by her husband or any relative of her husband for, or in connection with, any demand for dowry.
✓ Sections 3 and 4 of the Dowry Prohibition Act, 1961: These sections prohibit the giving or taking of dowry and prescribe penalties for demanding dowry.

Section 304B of the IPC is particularly relevant as it invokes a stringent standard due to the grave nature of the offense and the systemic harm it perpetuates. The section is applicable when a woman dies within seven years of her marriage under suspicious circumstances, and there is evidence of dowry-related harassment.

Arguments

Appellant’s Arguments:

• The High Court erred in overlooking substantial material indicating the involvement of Accused Nos. 2, 3, 4, and 5 in the alleged offense.
• The death occurred within seven years of marriage under suspicious circumstances, with clear evidence of dowry demands and harassment.
• The post-mortem report revealed ante-mortem injuries, indicating that the death was not a suicide but a case of forced strangulation.

Respondents’ Arguments:

• The accused had no prior criminal history.
• Some of the accused are women, warranting leniency.
• Certain co-accused had already been granted bail.

Issues Framed by the Supreme Court

1. Whether the impugned orders granting bail to the Respondent Nos. 2 (Accused Nos. 2, 3, 4, and 5) in these matters deserve to be sustained or set aside in light of the gravity of the offence alleged and the material available on record.

Treatment of the Issue by the Court: “The following table demonstrates as to how the Court decided the issues”

Authorities

The Court considered the following authorities:

✓ Ajwar v. Waseem, (2024) 10 SCC 768, Supreme Court of India: This case outlines the considerations for granting bail in serious criminal offenses. The Court referred to paragraph 26, which lists relevant factors such as the nature of accusations, the manner in which the crime is alleged to have been committed, the gravity of the offense, the role attributed to the accused, and the criminal antecedents of the accused.
✓ Chaman Lal v. State of U.P., (2004) 7 SCC 525, Supreme Court of India: Cited in Ajwar v. Waseem for factors to consider while granting bail.
✓ Kalyan Chandra Sarkar v. Rajesh Ranjan, (2004) 7 SCC 528, Supreme Court of India: Cited in Ajwar v. Waseem for factors to consider while granting bail.
✓ Masroor v. State of U.P., (2009) 14 SCC 286, Supreme Court of India: Cited in Ajwar v. Waseem for factors to consider while granting bail.
✓ Prasanta Kumar Sarkar v. Ashis Chatterjee, (2010) 14 SCC 496, Supreme Court of India: Cited in Ajwar v. Waseem for factors to consider while granting bail.
✓ Neeru Yadav v. State of U.P., (2014) 16 SCC 508, Supreme Court of India: Cited in Ajwar v. Waseem for factors to consider while granting bail.
✓ Anil Kumar Yadav v. State (NCT of Delhi), (2018) 12 SCC 129, Supreme Court of India: Cited in Ajwar v. Waseem for factors to consider while granting bail.
✓ Mahipal v. Rajesh Kumar, (2020) 2 SCC 118, Supreme Court of India: Cited in Ajwar v. Waseem for factors to consider while granting bail.
✓ P v. State of M.P., (2022) 15 SCC 211, Supreme Court of India: This case, decided by a three-Judge Bench, spells out the considerations that must weigh with the Court for interfering in an order granting bail to an accused under Section 439(1) CrPC.

Judgment

“How each submission made by the Parties was treated by the Court?” in [TABLE]

“How each authority was viewed by the Court?”

✓ Ajwar v. Waseem, (2024) 10 SCC 768: The Court thoroughly dealt with the observations regarding the grant of bail in grievous crimes in this case. It was used to emphasize the factors to be considered while granting bail in serious criminal offenses.
✓ Chaman Lal v. State of U.P., (2004) 7 SCC 525; Kalyan Chandra Sarkar v. Rajesh Ranjan, (2004) 7 SCC 528; Masroor v. State of U.P., (2009) 14 SCC 286; Prasanta Kumar Sarkar v. Ashis Chatterjee, (2010) 14 SCC 496; Neeru Yadav v. State of U.P., (2014) 16 SCC 508; Anil Kumar Yadav v. State (NCT of Delhi), (2018) 12 SCC 129; Mahipal v. Rajesh Kumar, (2020) 2 SCC 118: These cases were cited in Ajwar v. Waseem and were used to support the factors to consider while granting bail.
✓ P v. State of M.P., (2022) 15 SCC 211: This case was used to spell out the considerations that must weigh with the Court for interfering in an order granting bail to an accused under Section 439(1) CrPC.

What weighed in the mind of the Court?

The Supreme Court’s decision to cancel the bail of the father-in-law and mother-in-law was primarily influenced by the gravity of the allegations, the evidence of dowry demands, and the suspicious circumstances surrounding the death of the deceased. The Court emphasized that the High Court had adopted a seemingly mechanical approach in granting bail and failed to fully consider the stark realities of the allegations.

Fact:Law Ratio

The Court’s reasoning was based on the following:

• The deceased died within seven years of marriage under suspicious circumstances.
• There was evidence of dowry demands and harassment.
• The post-mortem report revealed ante-mortem injuries, indicating that the death was not a suicide.

The Court quoted:

“Stricter judicial scrutiny is necessary in matters where a young woman loses her life in her matrimonial home so soon after marriage, particularly where the record points to persistent harassment over unmet dowry demands.”

“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.”

“When a young bride dies under suspicious circumstances within barely two years of marriage, the judiciary must reflect heightened vigilance and seriousness.”

Key Takeaways

• Courts must exercise stricter judicial scrutiny in dowry death cases.
• The gravity of the allegations, evidence of dowry demands, and suspicious circumstances surrounding the death are critical factors to consider.
• A mechanical approach in granting bail can undermine the gravity of the offense and weaken public faith in the judiciary.

Directions

The Court directed the Trial Court to make endeavors to conclude the trial expeditiously, without being influenced by any of the observations contained in this judgment.

Development of Law

The ratio decidendi of the case is that in dowry death cases, courts must exercise heightened vigilance and seriousness, and a mechanical approach in granting bail can undermine the gravity of the offense and weaken public faith in the judiciary. This case reinforces the importance of considering the gravity of the allegations, evidence of dowry demands, and suspicious circumstances surrounding the death.

Conclusion

The Supreme Court’s judgment in Shabeen Ahmad vs. State of Uttar Pradesh underscores the need for stricter judicial scrutiny in dowry death cases. By canceling the bail of the father-in-law and mother-in-law, the Court has sent a strong message that such offenses will be treated with the seriousness they deserve.