The Delhi High Court has refused to grant regular bail to a mother-in-law accused in a dowry death case, observing that courts are required to exercise greater caution while considering bail applications in cases involving the death of a young bride within a short span of marriage.
Justice Swarana Kanta Sharma held that allegations of persistent harassment and dowry demands, when read together with an audio conversation recorded shortly before the deceased took her own life, lent seriousness to the accusations and did not justify grant of bail at this stage.
The Court observed: "A young life has been lost under tragic circumstances. The material collected during investigation, including the audio conversation between the deceased and her brother wherein she is heard crying and narrating the incident of being threatened with being paraded naked, when read together with the allegations of persistent harassment on account of non-fulfilment of dowry demands, lends seriousness to the allegations levelled against the applicant."
Background
The case arose from FIR No. 573/2024 registered at Police Station Vivek Vihar, Delhi under Sections 80(2), 85 and 3(5) of the Bharatiya Nyaya Sanhita, 2023.
Police received a PCR call informing them that a woman had died by suicide by hanging. Upon reaching the spot, officials found that the deceased had been taken down from the hanging position and placed on the bed by her husband and brother-in-law.
The Crime Team and FSL Team inspected the scene and the parents of the deceased, residents of Lakhimpur Khiri in Uttar Pradesh, were informed. The statement of the deceased's father was recorded by the SDM after the post-mortem examination.
According to the complainant, his daughter had married co-accused Deepak Kumar on 11.04.2024. Although considerable expenditure had been incurred on the marriage, her husband and in-laws continued to demand dowry and subjected her to physical and mental harassment.
Based on these allegations, the FIR came to be registered.
During investigation, it emerged that both the deceased and her husband were minors at the time of marriage. School records confirmed this fact, and the husband was apprehended.
Statements of witnesses were recorded under Section 180 BNSS.
The complainant also supplied a USB drive containing an audio recording of a conversation between the deceased and her brother dated 29.11.2024, shortly before the incident.
According to the prosecution, the audio recording captured the deceased narrating that her husband had abused her, threatened to tear her clothes and parade her naked in public. She further alleged that he had thrown her clothes outside the house and used filthy and derogatory language against her.
Subsequently, the present applicant, Ayodhya Devi, who is the mother-in-law of the deceased, along with the father-in-law, were arrested and a charge sheet was filed.
Counsel appearing for the applicant argued that the prosecution itself relied upon the audio recording, which, according to the defence, showed that the deceased was disturbed because of a quarrel arising out of an Instagram chat involving another girl and not because of dowry demands.
It was argued that throughout the conversation no allegation of dowry harassment had been levelled against the applicant.
The applicant further argued that she was not present in the house at the time of the quarrel or when the deceased committed suicide and that the essential ingredients of Section 80(2) BNS were not attracted.
It was also submitted that investigation had been completed, the charge sheet had already been filed, nothing remained to be recovered and that the applicant had clean antecedents and was not likely to tamper with evidence.
State Opposed Bail
Opposing the plea, the State argued that the statements of the parents and relatives consistently disclosed continuous demands for dowry and harassment on account of non-fulfilment of a demand of Rs.3 lakhs.
The prosecution also argued that the husband was a minor and had acted under the influence of his parents, including the present applicant. It was further argued that material witnesses had not yet been examined and there existed a possibility of influencing witnesses if the applicant was released on bail.
Audio Recording Showed Extreme Humiliation
After examining the material on record, the High Court noted that the deceased could be heard in the audio conversation narrating how she had been beaten by her husband after discovering messages exchanged with another girl.
According to the recording, her husband had thrown her clothes outside the house and threatened to parade her naked. She also expressed humiliation because her father-in-law had entered the room and seen her in that condition.
The Court noted that the father-in-law appeared to have been present during the incident and had failed to intervene. However, it also acknowledged that the present applicant was not present at that particular time.
Allegations Cannot Be Viewed In Isolation
Justice Sharma observed that the allegations could not be examined in isolation and had to be considered in their entirety.
The Court referred to specific allegations made by the complainant regarding an incident shortly before Rakshabandhan when the deceased had been beaten and thrown out of her matrimonial home during the night for non-fulfilment of dowry demands.
According to the prosecution, the deceased had then telephoned her brother from another person's mobile phone, following which she was brought back to her parental home. During her stay there, she informed her family that she was being harassed by the applicant and other accused persons for a demand of Rs 3 lakhs.
The Court noted that the complainant had explained the absence of any earlier police complaint by stating that the family wished that the deceased should settle peacefully in her matrimonial home and therefore avoided initiating criminal proceedings.
The Court took note of the statements of the father and other relatives that the deceased had repeatedly disclosed that the harassment was so unbearable that only death could provide relief.
According to the complainant, she occasionally made secret calls to family members from her sister-in-law's phone and informed them that she was being continuously harassed over the demand of Rs 3 lakhs.
On the night of 29.11.2024, she again called her brother while crying and informed him that her husband had torn her clothes and threatened to parade her naked.
Shortly thereafter, the family received information regarding her death.
The Court observed that the statements of the parents and relatives, read together with the audio recording, prima facie indicated continuous harassment for dowry.
Justice Swarana Kanta Sharma remarked that the case reflected the disturbing reality that young women are still driven to suicide because their parents are unable to satisfy unlawful dowry demands.
The Court observed: "The present case reflects a disturbing reality of society where, even today, a young girl aged about 19 years is alleged to have been driven to commit suicide because her parents were unable to fulfil an unlawful demand of ₹3 lakhs allegedly raised by her in-laws."
The Court further noted that the marriage had lasted only about eight months and that the material on record suggested persistent physical and mental harassment.
Supreme Court's Recent Warning On Dowry Death Cases
The High Court relied upon the recent Supreme Court judgment in Shabeen Ahmed v. State of Uttar Pradesh & Anr. (2025 INSC 307), wherein the apex court had emphasised that courts must exercise heightened vigilance while dealing with bail applications in dowry death cases.
Quoting the Supreme Court, the High Court observed that judicial orders in such cases carry an important social message and that a superficial application of bail principles risks weakening public confidence in the justice system's commitment to combating dowry deaths.
Another factor which weighed with the Court was that the FSL report regarding the conclusive cause of death was still awaited.
The Court also noted that material witnesses were yet to be examined before the Trial Court and there existed a possibility of interference with prosecution evidence or influencing witnesses if the applicant was released.
Accordingly, the Court held that it would not be in the interest of justice to enlarge the applicant on bail at this stage.
While dismissing the bail application, the Court clarified that the observations made in the order would not affect the merits of the trial. The Court granted liberty to the applicant to file a fresh bail application after examination of the complainant and requested the Trial Court to ensure that the complainant is examined at the earliest.
Case Title: BAIL APPLN. 920/2026 Ayodhya Devi @ Jyoti v. State (Govt. of NCT of Delhi)
Bench: Justice Swarana Kanta Sharma
Date of Decision: May 25, 2026
For Petitioner: Mr. Hitesh Aggarwal, Mr. Veer Chand Kumar, Advocates
For Respondent: Mr. Naresh Kumar Chahar, APP for the State. Mr. Mayank Mehandru, Ms. Charu Tandon, Mr. Raghav Tandon, Advocates for the complainant.
(The author of this article, Vatsal Chandra is a Delhi-based Advocate practicing before the courts of Delhi NCR.)
About the Author
Vatsal Chandra is a Delhi-based Advocate practicing before the courts of Delhi NCR. His practice spans insolvency matters, intellectual property rights, commercial and civil litigation, and family disputes.
