The
Supreme Court has emphasized the need for heightened vigilance in dowry death
cases, warning that granting bail without due scrutiny could undermine public
trust in the judiciary.
On Monday
(March 3), the Court cancelled the bail granted to the father-in-law and
mother-in-law of a deceased woman, Shahida Bano, citing prima facie evidence of
dowry demands and domestic violence. The Court criticized the "mechanical
approach" of the Allahabad High Court in granting bail, underscoring the
broader societal impact of such cases.
Case Background
Shahida
Bano was found dead in January 2024, within two years of her marriage, at her
matrimonial home. Her body was discovered hanging from a ceiling fan with a
dupatta around her neck. The post-mortem report suggested forced strangulation
before death, leading to the registration of a case under Section 304B (dowry
death) and Section 498A (cruelty) of the Indian Penal Code, along with
provisions of the Dowry Prohibition Act.
Despite
evidence of a pattern of dowry harassment, the Allahabad High Court granted
bail to the father-in-law, mother-in-law, and two sisters-in-law, citing a lack
of criminal antecedents. Challenging this order, the father of the deceased
appealed to the Supreme Court.
Supreme Court’s Observations
A bench
comprising Justice Vikram Nath and Justice Sandeep Mehta noted that the records
indicated severe brutality suffered by the victim due to persistent dowry
demands. The Court stressed the need for stricter judicial scrutiny in
cases where a young woman loses her life under suspicious circumstances soon
after marriage.
The Court
further warned that granting bail to the accused in such cases could weaken
public confidence in the criminal justice system.
“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.
Allowing alleged prime perpetrators of such heinous acts to remain on bail,
where the evidence indicates they actively inflicted physical and mental
torment, could undermine not only the fairness of the trial but also public
confidence in the judiciary.”
The bench
stressed that when the facts suggest direct involvement in a woman's death,
courts must act with utmost caution.
“Permitting
the father-in-law and mother-in-law to remain at large would run counter to the
ends of justice, especially when the evidence reflects a probable nexus between
their persistent dowry demands, physical cruelty, and the deceased’s death.”
Need for Deeper Scrutiny in Bail Matters
Expressing
concern over the continuing prevalence of dowry deaths, the Court emphasized
that judicial orders in such cases carry a significant social message.
“It is
unfortunate that in today’s society, dowry deaths remain a grave social
concern. Courts are duty-bound to undertake deeper scrutiny while granting bail
in such cases. When a young bride dies under suspicious circumstances within
barely two years of marriage, the judiciary must reflect heightened vigilance
and seriousness.”
While the
bail granted to the parents-in-law was revoked, the Supreme Court did not
interfere with the relief granted to the sisters-in-law.
Case Title
Shabeen
Ahmed v. State of Uttar Pradesh
