LexSHABEEN AHMAD versus THE STATE OF UTTAR PRADESH & ANR.
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[2025] 3 S.C.R. 367 : 2025 INSC 307 Shabeen Ahmad v. The State of Uttar Pradesh & Anr. (Criminal Appeal No. 1051 of 2025) 03 March 2025 [Vikram Nath* and Sandeep Mehta, JJ.] Issue for Consideration Matter pertains to the correctness of the order passed by the High Court granting bail to in-laws of the deceased wife, charged for causing dowry death of the deceased. Headnotes† Bail – Grant/cancellation of – In matters pertaining to dowry death – Death of the wife within two years of marriage in highly suspicious circumstances – Parents-in-law and sisters-in-law of the deceased wife charged for dowry death of the deceased – Trial court rejected the bail applications filed by the in-laws, however, the High Court granted bail – Sustainability: Held: Stricter judicial scrutiny necessary in matters where a young woman loses her life in her matrimonial home under highly suspicious circumstances so soon after marriage, particularly where the record points to persistent harassment over unmet dowry demands – Courts are duty-bound to undertake deeper scrutiny of the circumstances under which bail is granted in dowry death cases – Social message emanating from judicial orders in such cases cannot be overstated – Superficial application of bail parameters undermines the gravity of the offence and risks weakening public faith in the judiciary’s resolve to combat the menace of dowry deaths – It is this very perception of justice, both within and outside the courtroom, that courts must safeguard, lest there is a risk of normalizing a crime that continues to claim numerous innocent lives – On facts, seemingly mechanical approach adopted by the High Court in granting bail to the in-laws – While the court did note the absence of prior criminal records, it failed to fully consider the * Author 368 [2025] 3 S.C.R. Digital Supreme Court Reports stark realities of the allegations – Material on record suggests that parents-in-law had a principal role in pressurising the deceased with repeated demands for expensive items, subjected her to relentless cruelty, and infliction of brutal injuries – Gravity of the allegations demonstrates a strong prima facie case against them, thus, do not deserve continued protection of bail – As regards the sister-in-laws, material on record does implicate them but their role appears relatively less direct – Leniency shown towards them by not interfering with the bail granted – Thus, the bail granted to the parents-in-law cancelled and the bail granted to sister-in-laws upheld – Penal Code, 1860 – ss.304B, 498A – Dowry Prohibition Act, 1961 – ss.3, 4. [Paras 11-18] Case Law Cited Ajwar v. Waseem [2024] 5 SCR 575 : (2024) 10 SCC 768 – referred to. List of Acts Penal Code, 1860; Dowry Prohibition Act, 1961. List of Keywords Bail; Dowry death; Asphyxia due to ante-mortem strangulation; Dowry demands; Dowry-related cruelty; Unnatural death within seven years of marriage; Stricter judicial scrutiny of dowry deaths; Chain of events; Societal impact of dowry; Social justice and equality; Public confidence in criminal justice system; Mechanical approach in granting bail; Superficial application of bail parameters; Perception of justice; Judiciary’s resolve to combat the menace of dowry deaths. Case Arising From CRIMINAL APPELLATE JURISDICTION: Criminal Appeal No. 1051 of 2025 From the Judgment and Order dated 07.05.2024 of the High Court of Judicature at Allahabad, Lucknow Bench in CRMBA No. 4876 of 2024 With Criminal Appeal Nos. 1054, 1052 and 1053 of 2025 [2025] 3 S.C.R. 369 Shabeen Ahmad v. The State of Uttar Pradesh & Anr. Appearances for Parties Advs. for the Appellant: Paritosh Pandey, Ms. Rusheet Saluja. Advs. for the Respondents: Rohit K. Singh, Ms. Rashmi Singhania, Sanjeev Kumar Sharma, Ms. Shalini Sharma, Yash Singhania. Judgment / Order of the Supreme Court Judgment Vikram Nath, J. 1. Leave granted. 2. These four criminal appeals have been preferred by the common Appellant (original complainant) against four separate orders of the High Court of Judicature at Allahabad (Lucknow Bench), granting bail to the respective Respondent No.2 in each of the following Special Leave Petitions: • SLP (Crl.) No. 015156/2024 (Respondent No.2: Original Accused No.3, Smt. Tara Bano, mother-in-law of the deceased), • SLP (Crl.) No. 11355/2024 (Respondent No.2: Original Accused No.2, Mukhtar Ahmad, father-in-law of the deceased), • SLP (Crl.) No. 015157/2024 (Re
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