Delhi HC denies bail to mother-in-law in dowry death case

The Delhi High Court has refused to grant bail to a mother-in-law in a dowry death case following the death by suicide of her 19-year-old daughter-in-law eight months after the wedding.

Justice Swarana Kanta Sharma observed that a young life was lost under tragic circumstances and harassment had allegedly reached a stage where the deceased believed that the only escape from the conduct of her husband and in-laws was to take her own life. The deceased was found hanging in her matrimonial home in November 2024. Her family complained that the husband and the in-laws subjected her to physical and mental harassment for not fulfilling their demand of Rs 3 lakh as dowry. The recording of a call between the deceased and her brother a few hours before she took her life revealed that the husband used abusive and threatening language against her, tore her clothes after a quarrel and threatened to parade her naked on the streets.

Dismissing the bail plea by the mother-in-law on May 25, Justice Sharma said that since the forensic report on a conclusive cause of death was still awaited and material witnesses were yet to be examined before the trial court, releasing the present accused was not in the interest of justice, especially when there was a possibility of influencing the witnesses.

“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 Rs 3 lakh allegedly raised by her in-laws, including the present applicant, merely on account of her marriage into their family,” the court observed.

“A young life has been lost under tragic circumstances. The material collected during the 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,” it further said.

The mother-in-law claimed that the call recording between the deceased and her brother clearly reflected that she was disturbed because of a quarrel with her husband over an Instagram chat with another girl and not due to any alleged demand for dowry. It was also said that the mother-in-law was neither present at the time of the quarrel nor at the time when the deceased allegedly died by suicide.

Justice Sharma, however, asserted that according to the Supreme Court, in cases involving the alleged dowry death of a young bride within a short span of marriage, courts must exercise greater caution and undertake careful scrutiny of the surrounding circumstances.

It said that there were specific allegations of demand of dowry against the mother-in-law and material prima facie showed that the deceased had repeatedly informed her family that she was being harassed by her and other co-accused on account of non-fulfilment of their demand of Rs 3 lakh.

The court noted that in the audio conversation recorded only a few hours prior to the incident, the deceased specifically expressed her humiliation and distress on account the husband tearing her clothes and her father-in-law having seen her in that condition.

The court further noted that the deceased had allegedly repeatedly expressed to her parents and aunt that the only way to escape the torture was to end her life.

The police opposed the bail plea, stating that the statements of the parents and relatives of the deceased consistently disclosed continuous demands for dowry, along with harassment and threats.

It was argued that the mother-in-law was one of the principal accused, since the husband of the deceased was a minor and had acted under the direct influence of his parents.