Extra-Marital Relationship Per Se May Not Come Within Ambit of Sec.498-A IPC; No Blanket Prohibition Against Grant Of Bail In Every Case U/S.304B: Delhi High Court

of a young woman within a year of marriage, under unnatural circumstances, inevitably invites serious legal scrutiny. Yet, even in such tragic cases, the Court must assess whether the evidentiary foundation laid by the prosecution aligns with the statutory requirements.”

On a closer examination, the Bench found that prima facie the material on record revealed significant ambiguities and specificity that Section 304B IPC demands was lacking. The allegation of dowry demand, primarily the alleged demand for a car was mentioned only in the post-incident statements made by the family of the deceased. Pertinently, there was no contemporaneous complaint by the deceased, her parents, or any other relative during her lifetime alleging harassment or demand for dowry. “Prima facie, the record does not disclose any immediate or proximate instance of dowry-related cruelty or harassment that could satisfy the threshold of “soon before her death”, thereby creating further doubt in the Prosecution’s version”, it said.

The Bench further held, “ In the present case, the existence and fulfilment of such ingredients are issues to be adjudicated after conclusion of the trial. Nonetheless, at this preliminary stage, the Court is of the prima facie opinion that the invocation of Section 306 IPC does not warrant the denial of the relief of bail to the Applicant.”

It was also noticed that the father-in-law and brother-in-law of the deceased had already been discharged, and the sister-in-law, who faces identical charges as the Applicant, has been granted bail. Considering that the Applicant remained in judicial custody for over one year, he did not misuse the liberty of bail extended to him earlier, and the trial was likely to take time, the Bench directed the applicant to be released on bail on furnishing a personal bond for a sum of Rs 50,000 with two sureties. Few restrictions were also imposed by the High Court.

Cause Title: Karanjeet Singh v. State of NCT of Delhi (Neutral Citation: 2025:DHC:2820)

Appearance:

Applicant: Advocate R.S. Juneja, J.S. Juneja

Respondent: APP Amit Ahlawat, Advocates Aman Akhtar, Mohd. Imran, Shoaib Ikram, Rashid Khan, Inspector Arjun Singh

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