The Supreme Court cancels bail in a dowry death case, declaring that marriage is a sacred institution and not a commercial exchange. The bench criticised dowry practices, warning that material greed is destroying the purity of marital relationships today.
The Supreme Court revoked the bail granted to Raghvendra Singh (also known as Prince), who is accused of poisoning his wife, Aastha (or Saarika), to death just four months after their marriage.
The Court stated that allowing leniency in such heinous cases only serves to embolden offenders and erodes public trust in the justice system.
A bench consisting of Justices B V Nagarathna and R Mahadevan remarked that dowry death is not simply an offense against an individual, but rather a transgression against society as a whole.
The Bench remarked,
“This court cannot lose sight of the fact that marriage, in its true essence, is a sacred and noble institution founded on mutual trust, companionship, and respect. However, in recent times, this pious bond has regrettably been reduced to a mere commercial transaction. The evil of dowry, though often sought to be camouflaged as gifts or voluntary offerings, has in reality become a means to display social status and to satiate material greed.”
It highlighted that cases like these strike at the “collective conscience of society” and emphasized the need to fully apply the legal presumptions outlined in Section 113B of the Evidence Act when foundational facts regarding dowry death are established.
This decision was made in response to an appeal by the deceased woman’s father, Yogendra Pal Singh, who contested the Allahabad High Court’s bail decision.
The Supreme Court criticized the High Court for overlooking critical evidence, the gravity of the crime, and the statutory presumptions associated with Section 113B of the Evidence Act.
The bench further emphasized that the societal evil of dowry not only undermines the sanctity of marriage but also perpetuates systemic oppression and subjugation of women.
They stated,
“When such demands transgress the bounds of reason and culminate in cruelty, or worse, in the untimely death of a young bride, the offence transcends the private sphere of the family and assumes the character of a grave social crime. It ceases to remain a mere personal tragedy and becomes an affront to the collective conscience of the society. The phenomenon of dowry deaths represents one of the most abhorrent manifestations of this social malaise, where the life of a young woman is extinguished within her matrimonial home not for any fault of her own, but solely to satisfy the insatiable greed of others.”
The Court noted that the young woman died on 05.06.2023 in highly suspicious circumstances after allegedly being forced to consume a foul-smelling substance, as told to her sister moments before her death.
Background
The judgment states that her father had spent around Rs 22 lakh in cash, articles worth Rs 10 lakh, and jewellery worth Rs 15 lakh at the time of marriage, and soon after, she was harassed for more dowry, including a Fortuner car. Ten days before her death, she was sent back to her matrimonial home only after repeated assurances that the harassment would stop.
The Court recorded that at a family function on 04.06.2023, there was a quarrel between the husband and the deceased. Around 1:30 am, the deceased called her elder sister in distress, crying and saying that her husband and his relatives had “forcibly administered some foul-smelling substance to her”.
She was taken to the hospital with froth coming out of her mouth and later died while being shifted to Kanpur. The post-mortem did not initially confirm the cause of death, but the FSL report later showed aluminium phosphide poisoning. There was also an abrasion on her left forearm, suggesting possible restraint.
The father told the police that his daughter made a dying declaration at the hospital, again saying that her husband, uncle and aunt forced her to consume the “smelly substance”. Statements under Section 161 CrPC from the mother and sisters also supported the allegations of dowry harassment.
The Supreme Court noted that these consistent statements created a strong prima facie case.
The Court criticised the delay and deficiencies in the initial investigation, including the late arrest of the husband while other accused were never arrested. The Assistant Prosecution Officer had also pointed out serious lapses which led to the transfer of the case to CB-CID. The Court held that the High Court failed to consider the influence of the accused’s politically connected family and the risk of witness intimidation.
Legal Significance
The Supreme Court relied heavily on Section 304B IPC, Section 498A IPC and Section 113B of the Evidence Act, noting that the death took place within four months of marriage and was preceded by continuous dowry-related cruelty.
Section 304B IPC: Dowry Death
- This section deals with dowry death.
- If a woman dies due to burns, bodily injury, or any unnatural circumstances within 7 years of marriage, and she was subjected to cruelty or harassment for dowry by her husband or his relatives soon before her death, it is considered a dowry death.
- Punishment: Minimum 7 years, which may extend to life imprisonment.
Section 498A IPC: Cruelty by Husband or Relatives
- This section punishes the husband or his relatives for subjecting a woman to cruelty.
- “Cruelty” includes:
- Any wilful conduct likely to drive the woman to suicide or cause serious injury.
- Harassment with a demand for dowry.
- Punishment: Up to 3 years imprisonment + fine.
- The offence is cognizable, non-bailable, and non-compoundable.
Section 113B of the Evidence Act : Presumption as to Dowry Death
- This section provides a legal presumption in dowry death cases.
- When it is shown that:
- A woman died under unnatural circumstances within 7 years of marriage, AND
- She faced dowry-related cruelty or harassment soon before her death,
- Then the court must presume that the husband or relatives caused the dowry death.
- This helps the prosecution because it shifts the burden of proof onto the accused.
It said that once these foundational facts are shown, the presumption of dowry death is mandatory. The Court also cited earlier decisions emphasising that bail orders passed without considering relevant materials must be set aside.
It explained that granting bail in such cases weakens public confidence and ignores the societal impact of dowry deaths.
The Court observed that dowry death is not just a crime against an individual but a crime against society, adding that marriage is a sacred institution that is being reduced to a commercial transaction.
It said the “evil of dowry leads to the exploitation and even death of young women who enter their matrimonial homes with trust and expectations.”
The judgment strongly said that misplaced leniency in such cases encourages offenders and harms public faith in the justice system.
Also Read: Dowry Death? Dying Declaration Sends Mother-In-Law To Jail For Life: District Court
The Supreme Court therefore set aside the High Court order and cancelled the bail granted to the husband.
The direction states,
“The bail granted to Respondent No. 1 is hereby cancelled, and he is directed to surrender to custody forthwith, failing which, the concerned authorities shall take him into custody immediately.”
The Court clarified that this decision relates only to the bail issue and that the trial will continue independently.
The bench stressed that a strong judicial response is crucial to ensure justice in this case and to convey a clear message that society and the law will not tolerate atrocities stemming from the dowry system. They called attention to the alarming increase in dowry death cases, asserting the need for rigorous judicial examination.
Allowing the accused to remain free under such circumstances would undermine the deterrent purpose of Sections 304B and 498A of the IPC.
Case Title: Yogendra Pal Singh v. Raghvendra Singh @ Prince & Another (Neutral Citation: 2025 INSC 1367)
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