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Chattisgarh High Court
Jhumuk Lal Sahu vs State Of Chhattisgarh on 25 March, 2026
Author: Ramesh Sinha
Bench: Ramesh Sinha
1
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
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.
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
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
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.
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
