Chattisgarh High Court
Jhumuk Lal Sahu vs State Of Chhattisgarh on 25 March, 2026
Author: Ramesh Sinha
Bench: Ramesh Sinha
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2026:CGHC:14271
NAFR
KUNAL
DEWANGAN
Digitally
HIGH COURT OF CHHATTISGARH AT BILASPUR
signed by
KUNAL
DEWANGAN
MCRC No. 2803 of 2026
1 - Jhumuk Lal Sahu S/o Biseshar Sahu Aged About 62 Years R/o Village
Angara, P.S. Kurud, Distt. Dhamtari, Chhattisgarh.
2 - Smt. Jageshwari Sahu W/o Jhumuk Lal Sahu Aged About 53 Years
R/o Village Angara, P.S. Kurud, Distt. Dhamtari, Chhattisgarh.
... Applicants
versus
State of Chhattisgarh Through Station House Officer, Kurud, Distt.
Dhamtari, Chhattisgarh.
... Non-Applicant
For Applicants : Ms. Aditi Singhvi, Applicant
For Non-Applicant/State : Ms. Smriti Shrivastava, Panel Lawyer.
Hon'ble Mr. Ramesh Sinha, Chief Justice
Order on Board
25.03.2026
1.This is the First bail application filed under Section 483 of the Bhartiya Nagarik Suraksha Sanhita, 2023 for grant of regular bail to the applicants who have been arrested in connection with Crime No.346/2025 registered at Police Station - Kurud, District Dhamtari (C.G.), for the offence punishable under Sections 80(2), 3(5) of the Bharatiya Nyaya Sanhita, 2023.
2. The case of the prosecution, in brief, is that the deceased Bhavna Sahu was married to Ravi Kumar Sahu, son of the present 2 applicants Jhukum Lal Sahu and Jageshwari Sahu, on 08.03.2019 as per social customs. It is alleged that after about 2-3 years of marriage, the deceased was subjected to continuous physical and mental cruelty by her husband and in-laws, particularly by the present applicants, on account of dowry demands and suspicion over her character. The prosecution case is that the applicants used to taunt and harass the deceased for not bringing sufficient dowry articles such as a washing machine, fridge, utensils, and jewellery, and also treated her in a humiliating manner, thereby causing grave mental distress.
3. It is further case of the prosecution is that due to such persistent harassment and torture, the deceased, on 02.11.2025, poured kerosene oil on herself and set herself on fire at her matrimonial home, as a result of which she sustained severe burn injuries and was admitted to Kalda Burn Hospital, Raipur, where she subsequently succumbed to her injuries during treatment. The admission slip of the hospital records the cause of burn injuries as self-inflicted by pouring kerosene. During the course of investigation, the dying declaration of the deceased was recorded by the Executive Magistrate, wherein she specifically alleged that she took the extreme step due to the taunts and ill-treatment meted out to her by her father-in-law Jhukum Lal Sahu and mother-in-law Jageshwari Sahu, who allegedly treated her like a maid. It has also come on record that her statements were recorded on a mobile phone during hospitalization, wherein she held her in-laws responsible for any harm caused to her.
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4. On the basis of such material collected during investigation, including the dying declaration and other evidence in the case diary, the prosecution asserts that there are prima facie grounds to believe that the applicants subjected the deceased to cruelty in connection with dowry demands, which ultimately led her to commit suicide. Accordingly, offences under the relevant provisions of law have been registered, and after completion of investigation, charge- sheet has been filed against the applicants.
5. Learned counsel for the applicants submits that the applicants are innocent and have been falsely implicated in the present case. It is contended that the marriage between the deceased Bhavna Sahu and Ravi Kumar Sahu was solemnized on 08.03.2019 as per social customs, and the deceased lived a normal married life for several years. The applicants never demanded any dowry nor subjected the deceased to any form of cruelty. It is further submitted that the deceased was suffering from various ailments and was mentally distressed, due to which she used to frequently visit her parental home after minor matrimonial disputes. Meetings were also convened within the community to resolve such issues, and there was no persistent or grave harassment attributable to the applicants.
6. It is further submitted that the unfortunate incident is a case of suicide, as is evident from the hospital record itself, wherein it is mentioned that the deceased poured kerosene on herself and set herself ablaze. The allegations of dowry demand and harassment are omnibus, vague, and have been falsely levelled after the 4 incident. The applicants have not played any active role in the alleged offence, and there is no independent material on record to corroborate the prosecution story except the alleged dying declaration, which is disputed. It is also submitted that the provisions relating to dowry death are not attracted in the present case, as the marriage had subsisted for more than seven years.
7. It is also contended that applicant Jhukum Lal Sahu is about 62 years of age and is suffering from serious ailments such as asthma and tuberculosis, while applicant Jageshwari Sahu is also suffering from thyroid-related issues, and their continued incarceration would cause undue hardship. It is lastly contended that the husband and sister-in-law of deceased I.e son and daughter of the present applicants have been enlarged on anticipatory bail by the trial Court. The applicants undertake to cooperate with the trial, are ready to furnish adequate surety, and there is no likelihood of absconding or tampering with evidence. Therefore, it is prayed that the applicants be enlarged on bail.
8. On the other hand, learned counsel for the State submits that the applicants are involved in a serious offence relating to dowry harassment and abetment of suicide, wherein the deceased succumbed to burn injuries after being subjected to continuous physical and mental cruelty. It is contended that the dying declaration of the deceased, recorded by the Executive Magistrate, clearly implicates the applicants, and the same is duly supported by other material collected during investigation. It is further submitted that considering the gravity of the offence, the specific allegations of 5 harassment for dowry, and the material available on record, there exists a prima facie case against the applicants. Therefore, the applicants do not deserve to be enlarged on bail at this stage.
9. I have heard learned counsel appearing for the parties and perused the case diary.
10. Considering the facts and circumstances of the case, particularly the serious nature and gravity of the allegations involving cruelty and harassment of a married woman leading to her unnatural death by burn injuries, and the specific role attributed to the applicants, this Court finds that there exists a prima facie case against them. The material available on record, including the dying declaration of the deceased recorded by the Executive Magistrate, clearly indicates that the deceased had attributed responsibility to the applicants for the mental and physical harassment suffered by her, which ultimately compelled her to take the extreme step. Further, having regard to the nature of the offence, the severity of punishment prescribed, and the overall circumstances emerging from the case diary, this Court is of the considered view that it is not a fit case for grant of bail at this stage. Without expressing any opinion on the merits of the case, the bail application filed by the applicants is accordingly dismissed.
11. Accordingly, the bail application of the applicants - Jhumuk Lal Sahu and Smt. Jageshwari Sahu, filed under Section 483 of the BNSS, involved in Crime No. 346/2025 registered at Police Station
- Kurud, District Dhamtari (C.G.), for the offence punishable under Sections 80(2), 3(5) of the BNS, is rejected.
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12. Needless to say that the trial Court concerned is at liberty to proceed and conclude the trial expeditiously.
13. Office is directed to send a certified copy of this order to the trial Court concerned for necessary information and compliance forthwith.
- Sd/-
(Ramesh Sinha)
Chief Justice
Kunal