Allahabad High Court
MEENA DEVIversusSTATE OF U.P.
- Decided
- Bench
- SAMEER JAIN
Holding
The court held that Meena Devi is entitled to be released on bail.
Summary
The High Court considered a bail application filed by Meena Devi, the mother‑in‑law of a deceased woman who allegedly died by suicide within two months of marriage. The applicant argued that the death was a suicide, citing the post‑mortem report showing a hanging with no other injuries, and that she had no criminal history and faced the same allegations as her son‑in‑law, who had already been released on bail. The State opposed bail but did not dispute the factual contentions. The Court noted the prima‑facie evidence of suicide, the lack of specific allegations against the applicant, and the precedent of bail granted to the co‑accused. Consequently, the Court allowed the bail application, directing the applicant to furnish a personal bond and two sureties with standard conditions. The order was made without expressing any opinion on the merits of the underlying criminal case.
Issues considered
- Whether the applicant is entitled to bail under Sections 80(2), 85 of the IPC and Sections 3 and 4 of the Dowry Prohibition Act given the prima facie evidence of suicide.
- Whether the applicant’s lack of criminal history and the bail granted to a co‑accused justify granting bail in this case.
Legislation cited
- Dowry Prohibition Act, 1961 — s. 3, 4
- Indian Penal Code — s. 80(2), 85
Subjects
- bail
- dowry death
- suicide
- Indian Penal Code
- Dowry Prohibition Act
- criminal procedure
- mother‑in‑law
- false allegation
Judgment
HIGH COURT OF JUDICATURE AT ALLAHABAD
CRIMINAL MISC. BAIL APPLICATION No. - 15050 of 2026
Meena Devi
.....Applicant(s)
Versus
State of U.P.
.....Opposite
Party(s)
Counsel for Applicant(s) : Om Prakash Gupta, Priyavrat Tripathi
Counsel for Opposite Party(s) : G.A.
Court No. - 66
HON'BLE SAMEER JAIN, J.
1. Heard Sri Om Prakash Gupta, learned counsel for the applicant and Sri
Kunwar Tejandra Bahadur, learned AGA for the State.
2. The instant bail application has been filed seeking release of the applicant
on bail in Case Crime No. 21 of 2026, under Sections 80(2), 85 BNS and
Section 3/4 D.P. Act, Police Station Vishunpura, District Kushinagar during
pendency of the trial.
3. Learned counsel for the applicant submits, applicant is mother-in-law of
the deceased and on the basis of false allegation she has been made accused
in the present matter along with others including father-in-law of the
deceased Pramod Jaiswal and co-accused Pramod Jaiswal has been released
on bail by this Court with a very detailed and reasoned order dated
23.04.2026 passed in Criminal Misc. Bail Application No. 7442 of 2026 and
as far as allegations are concerned, the case of applicant is at par with him.
4. He further submits, from the post mortem report it reflects, deceased died
due to hanging and apart from the ligature mark deceased did not sustain any
injury and even her hyoid bone was found intact and therefore prima facie it
appears to be a case of suicidal death.
5. He further submits, though deceased died within two months of her
marriage in her matrimonial home but this fact itself suggests that actually it
is not a case of dowry death as it is hard to believe that in such a short span
she would have tortured for dowry in such manner that she had to commit
suicide.
BAIL No. 15050 of 2026
2
6. He further submits, it reflects, after marriage deceased either could not
cope up with her matrimonial duties or against her wishes her marriage was
performed with the son of applicant, therefore, she committed suicide.
7. He further submits, applicant is not having any criminal history and there
is no specific allegation against her and in the present matter she is in jail
since 20.01.2026.
8. Per contra, learned AGA opposed the prayer for bail but could not dispute
the argument on facts advanced by learned counsel for the applicant.
9. I have heard learned counsel for the parties and perused the record of the
case.
10. However, applicant is mother-in-law of the deceased and her daughter-
in-law died within two months of her marriage in her matrimonial home
under abnormal circumstances and there is also allegation of torture for
demand of additional jewellery and money but post mortem report suggests
that deceased died due to hanging and apart from the ligature mark deceased
did not sustain any other injury and even her hyoid bone was found intact,
therefore, prima facie it appears to be a case of suicidal death and
considering the short duration of marriage, the argument advanced by
learned counsel for applicant in this regard cannot be ruled out at this stage.
11. Further, even father-in-law of the deceased Pramod Jaiswl has been
released on bail by this Court and as far as allegations are concerned case of
applicant is at par with him.
12. Further, there is no specific allegation against applicant and applicant is
not having any criminal history and she is lady and in the present matter she
is in jail since 20.01.2026.
13. Therefore, considering the facts and circumstances of the case discussed
above, in my view, applicant is entitled to be released on bail.
14. Accordingly, without expressing any opinion on the merits of the case,
the instant bail application is allowed.
15. Let the applicant - Meena Devi be released on bail in the aforesaid case
on furnishing a personal bond and two sureties each in the like amount to
the satisfaction of the court concerned with the following conditions:-
BAIL No. 15050 of 2026
3
(i) The applicant shall appear before the trial court on the dates fixed, unless
her personal presence is exempted.
(ii) The applicant shall not directly or indirectly, make inducement, threat or
promise to any person acquainted with the facts of the case so as to dissuade
him from disclosing such facts to the Court or any police officer or tamper
with the evidence.
(iii) The applicant shall not indulge in any criminal and anti-social activity.
16. In case of breach of any of the above condition, the prosecution will be
at liberty to move an application before this Court for cancellation of the
bail of the applicant.
17. It is clarified that the observations made herein are limited to the facts
brought in by the parties pertaining to the disposal of bail application and the
said observations shall have no bearing on the merits of the case during trial.
May 5, 2026
AK Pandey
(Sameer Jain,J.)
Digitally signed by :-
ANUPAM KUMAR PANDEY
High Court of Judicature at Allahabad
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