Mr. Vikrant Chawla and Mr. Vignesh v. State (NCT of Delhi)

1. Allowed, subject to all just exceptions.

2. Applications stand disposed of. BAIL APPLN. 3708/2025 BAIL APPLN. 3711/2025 BAIL APPLN. 3717/2025

3. By way of these applications, the applicants are seeking grant of anticipatory bail in case out of FIR bearing no. 553/2025, registered at Police Station Begumpur, Delhi, for the commission of offence punishable under Sections 80/85/3(5) of the Bharatiya Nyaya Sanhita, 2023 (hereafter „BNS‟).

4. Brief facts of the case, as per status report, are that a PCR call was received at P.S. Begumpur on 22.08.2025 regarding the hanging of a woman. Upon visiting the place of incident in Sector 23, Rohini, Delhi, the police had found one Nikita Gambhir, aged 25 years, lying on the bed. After inspecting the spot, the body of the deceased was shifted to Sanjay Gandhi Hospital, where she was declared “brought dead” vide MLC No. 24770/25. No suicide note had been found at the spot. It then came to light that the deceased had married Sourav, son of Veer Bhan, resident of Hari Vihar, Dwarka, on 18.04.2024; and as she had died an unnatural death, the SDM, Kanjhawala was informed. On 23.08.2025, the SDM recorded the statements of the family members of the deceased, wherein they alleged that the deceased had ended her life due to persistent dowry demands and cruelty at the hands of her husband, in-laws, and other relatives. The mother and brother of the deceased alleged that deceased’s husband, along with his parents, brothers Gaurav and Rahul, and their wives Dimpy and Akansha, had been continuously demanding articles and had subjected her to beatings and torture whenever the demands were not met. They further alleged that recently the deceased was being harassed on account of the illegal demand of a Scorpio car. It was specifically alleged that on 12.08.2025 and 13.08.2025, the deceased had been beaten by her husband on the instigation of his family members and was thrown out of the matrimonial home with a warning that she would be allowed to return only when her family fulfilled the demand of a Scorpio car. Her mobile phone had also been withheld by the in-laws. Unfortunately, she committed suicide by hanging herself, in her parental home, on 22.08.2025. The postmortem of the deceased was conducted on 24.08.2025, and thereafter, on the recommendation of the Executive Magistrate, the present FIR was registered.

5. The learned senior counsel appearing for the applicants argues that that there are no specific allegations against the present applicants and they have been falsely implicated in this case. It is argued that the dispute, if any, or any incidents of marital discord could have, though not admitted, taken place between the husband (co-accused) and the deceased, but the present applicants have no connection with the same. It is argued that the applicant in BAIL APPLN. 3708/2025 and applicant in BAIL APPLN. 3711/2025 are brother-in-law and sister-in-law of the deceased, who were living separately and the entire complaint does not mention any specific allegations against them. It is also argued that the applicant in BAIL APPLN. 3717/2025 is father-in-law of the deceased and there are also no specific allegations against him. It is also contended that the deceased did not file any complaint immediately after 13.08.2025 and the incident took place about 9 days after the deceased had left her matrimonial home, and thus, there was no instigation by the accused persons. It is submitted that the applicants are willing to join the investigation, and nothing is to be recovered from them; therefore, they be granted anticipatory bail.

6. On the other hand, the learned APP for the State argues that within 15 months of marriage, the deceased has died under unnatural circumstances, and it is evident from the statements of the witnesses that she had been tortured and harassed for demand of dowry. The learned APP also points out that the complaint as well as the statements of the witnesses recorded during investigation specifically discloses the allegations against the accused persons including applicants herein. The learned APP also draws this Court’s attention to the transcript of the conversation between the deceased and her mother. It is further submitted that the applicants have not yet joined the investigation and their mobile numbers are also switched off. It is thus prayed that these bail applications be dismissed.

7. This Court has heard arguments addressed on behalf of the accused/applicants as well as the State, and has perused the material available on record.

8. In the present case, this Court has gone through the statements of the witnesses and family members of the deceased recorded by the police under Section 180 of BNSS. The mother of the deceased has specifically alleged that the father-in-law of the deceased (applicant in BAIL APPLN. 3717/2025) had asked for dowry from the family of deceased at the time of marriage, including gold chains, ornaments, as well as ₹10 lakhs in cash. She further alleges that accused persons, including brother-in-law Rahul (applicant in BAIL APPLN. 3708/2025), were pressuring the deceased in June 2024 for bringing ₹10 lakhs from her brother, else they would stop her food. The deceased’s mother also alleges that at the time of birth of first child of the deceased in January 2025, the accused persons, including father-in-law Veer Bhan and brother-in-law Rahul, had demanded a Scorpio car, and told them that the same must be given to them now as it was not given in dowry at the time of marriage. As alleged, in pursuance of this demand, the brother of the deceased had even visited the showroom to obtain a quotation for the said car; however, the price was found to be beyond their financial means. The deceased however continued to be subjected to persistent taunts. Consequently, the parents of the deceased encashed a fixed deposit of ₹3.50 lakh and the same was deposited in the account of the deceased on 15.02.2025. Nevertheless, even thereafter, she continued to be harassed and subjected to cruelty on account of the demand for the car and allegedly, the accused persons used to threaten to throw her out of the house or even kill her if the demand for the car was not met. The deceased’s mother has also narrated as to how the deceased’s husband Gaurav used to torture her physically and mentally.

9. This Court has also taken note of the statement of the brother of the deceased, who has corroborated the statement of his mother, and alleged that the deceased was subjected to physical, mental and emotional cruelty by the accused persons and was forced to commit suicide as they were not able to fulfil the illicit dowry demands of the accused persons.

10. This Court’s attention has also been drawn to the transcript of conversations between the deceased and her mother on 12.08.2025 and 13.08.2025 which reveal the gravity of the situation. The deceased had informed her mother that she had been thrown out of the car by her husband and was left standing on the roadside. Since her own mobile phone had been taken away, she had to borrow a phone from a bystander to make the call. In that conversation, she disclosed that she had been brutally beaten by her husband for nonfulfilment of dowry demands, and further, he had threatened her that he would get her beaten by her brother-in-law Sourav as well. The deceased also expressed her desire to go straight to the police station to lodge a complaint against her husband and in-laws. This conversation prima facie demonstrates that the deceased had been subjected to severe cruelty and harassment in close proximity to the time of her death.

11. It has been contended on behalf of the applicants that the father-in-law resided on the ground floor of the house, while the brother-in-law Rahul resided on the second floor, and the deceased was living with her husband on the third floor. However, the mere fact that they were residing on different floors of the same house does not imply that they were not in contact with the deceased or that they could not have subjected her to cruelty. Evidently, the entire family was living in one house, though on separate floors, and thus, on this ground alone, the allegations against them cannot be considered as improbable or false.

12. Further, the sister-in-law (bhabhi) of the deceased had lodged a complaint on 24.08.2025, alleging that she had received threatening calls from unknown numbers. During these calls, she was told: “Humne pata lagwa liya hai ki abhi tak teri police ne statement record nahi ki hai, humare hisaab se statement dekar maamla khatam kar, warna abhi to sirf bhabhi gayi hai, agla number tera aur tere bachon ka bhi ho sakta hai.” Thus, the callers demanded that they settle the matter or else, face dire consequences.

13. This Court also takes into account the fact that despite several notices having been served upon the applicants herein, they have not joined the investigation yet. Further, as informed by the learned APP for the State on instructions from I.O., their mobile phones have been found to be switched off.

14. It is profoundly unfortunate that, even in present times, many women continue to suffer cruelty within their matrimonial homes, inter alia, for demand of dowry. Such cruelty not only robs women of their dignity but, in many tragic cases, also costs them their lives. These incidents are a stark reminder that the fight against social evils like dowry and domestic violence is far from over. Thus, considering the above facts and circumstances, this Court is not inclined to grant anticipatory bail to the applicants – Veer Bhan and Rahul Sahni. Their bail applications are dismissed.

15. However, as far as the applicant Akansha, i.e. wife of Rahul Sahni, is concerned, a perusal of the transcripts of the telephonic conversations between the deceased and her mother dated 13.08.2025, which have been placed on record, suggests that applicant Akansha had expressed her empathy at the alleged atrocities committed upon the deceased and had given certain advices to her. The relevant extract of the transcript mentions: “Akansha Bhabhi hai na... unhone bola ki ase maat bolo. Mujhe bhi gussa aa rha hai...usko maat maro. Mai jyda bolti toh meri bhi ladai ho jati. Vo kehri mere saath bhi same karte the pehle. Mai toh alag ho gyi mere saath bhi yehi karte the”. Thus, the deceased herself told her mother on 13.08.2025 that Akansha had expressed anger at the conduct of the family members, and had confided that she too had earlier faced similar treatment before distancing herself from other family members.