The Supreme Court granted bail to 65-year-old Jadhav Mamatha, convicted under Section 304-B IPC in a dowry death case, suspending her seven-year sentence pending appeal and raising questions about evidence and due process.
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NEW DELHI: In an order on November 10, 2025, the Supreme Court of India granted bail to Jadhav Mamatha (the appellant), a 65-year-old mother-in-law of the deceased convicted in a dowry death case by the Telangana High Court. The bench comprising Justice J.B. Pardiwala and Justice K.V. Viswanathan passed the order while hearing SLP (Crl.) No. 13634/2023, arising out of a 2023 judgment of the High Court of Telangana at Hyderabad.
The appellant, mother-in-law of the deceased, had been convicted under Sections 302 & Section 304-B of the Indian Penal Code (IPC), the provision that deals with dowry death. The Supreme Court’s order comes as a relief to the elderly appellant, who had been sentenced to seven years of rigorous imprisonment.
Background of the Case
The case arose from the tragic death of a woman allegedly subjected to harassment for dowry. The Trial Court initially acquitted all the accused, the deceased’s husband, father-in-law, and mother-in-law, of charges under Sections 302 and 304-B IPC.
However, the de facto complainant appealed to the Telangana High Court, which reversed the acquittal and held all three accused guilty of dowry death under Section 304-B IPC.
By the time the case reached the Supreme Court, the father-in-law had passed away, leaving only the mother-in-law, Jadhav Mamatha, to pursue the appeal.
Medical Evidence and High Court Observations
The post-mortem report cited intra-cranial hemorrhage as a post-surgical sequel resulting in cardio-respiratory arrest as the cause of death. During cross-examination, the medical officer (PW-5) admitted that the deceased had an artificial left eye and that the fatal injury might have been accidental, caused by a piercing injury affecting the brain area behind the eye.
The Supreme Court noted these inconsistencies and observed that the manner in which the trial was conducted raised concerns about the evidentiary basis of the conviction.
ALSO READ: Dowry Death? Dying Declaration Sends Mother-In-Law To Jail For Life: District Court
High Court’s Findings and Observations
The Telangana High Court, led by Justice M. Laxman and Justice G. Anupama Chakravarthy, re-evaluated the entire evidence and found that the Trial Court had wrongly given the benefit of doubt to the accused. The Bench observed that the deceased, Archana, had died within a year of marriage under unnatural circumstances at her matrimonial home, following continuous dowry harassment by her husband and in-laws.
The Court relied on witness testimonies, including those of the victim’s parents, showing that the accused demanded an additional ₹50,000 as dowry and that the deceased had expressed fear for her life shortly before her death. The post-mortem revealed scratch and abrasion marks on the neck and face, which the Court held could not be attributed to an accident.
Since the death occurred inside the accused’s house, the Court ruled that it was their duty to explain the cause of death, which they failed to do. Applying the presumption under Section 113-B of the Indian Evidence Act, the Court held that the death satisfied all conditions of Section 304-B IPC (dowry death). Consequently, the husband and mother-in-law were convicted and sentenced to eight and seven years’ imprisonment, respectively.
Order of the Supreme Court
Justice Pardiwala observed that,
“It appears that the High Court while reversing the acquittal held the appellant herein along with the other two co-accused guilty for the offence of Section 304-B of the IPC only. In short, the High Court has not brought the case within the ambit of murder but seems to have proceeded on the footing that the deceased committed suicide on account of harassment for want of dowry.”
After hearing Senior Advocate Sudhanshu S. Choudhari for the appellant and Advocate Kumar Vaibhaw for the State of Telangana, the Court ordered:
“Without observing anything further, we suspend the substantive order of sentence of seven years’ rigorous imprisonment as imposed by the High Court and order release of the appellant on bail pending final disposal of her appeal before us.”
The Court directed that Jadhav Mamatha be released on bail forthwith, subject to conditions determined by the original trial court.
Legal Significance
Section 304-B IPC prescribes punishment for dowry deaths, typically involving women who die under unnatural circumstances within seven years of marriage due to harassment over dowry demands. Convictions under this section carry a minimum sentence of seven years, extendable to life imprisonment.
ALSO READ: Vismaya Dowry Death: Supreme Court Suspends Husband Kiran Kumar’s 10-Year Sentence
The concept of dowry is not defined in the Indian Penal Code, 1860 (IPC), but is explained under the Dowry Prohibition Act, 1961. It refers to any property or valuable security given or agreed to be given, directly or indirectly, by one party to a marriage to the other, or by their families, before, during, or after the marriage, in connection with the marriage.
Dowry death is defined under Section 304-B of the IPC, while Section 113-B of the Indian Evidence Act, 1872 establishes a presumption regarding such deaths.
According to Section 304-B IPC, if a woman dies within seven years of marriage under unnatural or suspicious circumstances and it is proven that she was harassed or subjected to cruelty by her husband or his relatives in connection with dowry demands, such death is treated as a dowry death.
Essential Conditions
For a case to qualify as a dowry death:
- The woman’s death must occur by burns, bodily injury, or under abnormal circumstances.
- It must happen within seven years of marriage.
- She must have been subjected to cruelty or harassment by her husband or his relatives.
- The harassment must relate to a demand for dowry, occurring soon before her death.
Punishment
Under Section 304-B(2) IPC, anyone found guilty of dowry death faces a minimum of seven years’ imprisonment, which may extend to life imprisonment.
Case Title:
JADHAV MAMATHA VERSUS SINDE NAGO RAO & ANR.
Special Leave to Appeal (Crl.) No.13634/2023
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