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Savitri Bai @ Chandi Bai vs The State Of Madhya Pradesh
2025 Latest Caselaw 9975 MP

Citation : 2025 Latest Caselaw 9975 MP
Judgement Date : 8 October, 2025

Madhya Pradesh High Court

Savitri Bai @ Chandi Bai vs The State Of Madhya Pradesh on 8 October, 2025

Author: Sanjeev S Kalgaonkar
Bench: Sanjeev S Kalgaonkar
         NEUTRAL CITATION NO. 2025:MPHC-IND:29414




                                                                1                           MCRC-43632-2025
                              IN     THE       HIGH COURT OF MADHYA PRADESH
                                                      AT INDORE
                                                        BEFORE
                                      HON'BLE SHRI JUSTICE SANJEEV S KALGAONKAR
                                                  ON THE 8 th OF OCTOBER, 2025
                                            MISC. CRIMINAL CASE No. 43632 of 2025
                                           SAVITRI BAI @ CHANDI BAI AND OTHERS
                                                           Versus
                                              THE STATE OF MADHYA PRADESH
                           Appearance:
                                   Shri Harshwardhan Sharma, Advocate for the applicants.
                                   Shri Apoorv Joshi, Govt. Advocate for the respondent/State.
                                   Shri Ali Husain Mansuri, Advocate for the respondent [COMP].

                                                                    ORDER

This first application has been filed by the applicants under Section 483 of BNSS, 2023 for grant of bail in connection with Crime No.582 of 2025 registered at Police Station - Rajgarh, District - Rajgarh(M.P.) for offence punishable under Sections 108, 85 and 3(5) of BNS, 2023. Applicants are in judicial custody since 02.09.2025.

Heard the arguments.

Perused the grounds for grant of bail stated in the application, case diary

and the relevant material on record.

Learned counsel for the applicants, in addition to the grounds mentioned in

the application, submits that the applicants are falsely implicated in the alleged

offence merely for the reason that applicant No.1 Savitri Bai @ Chandi Bai is

sister-in-law(Jaithani) and Kanchan Bai @ Kanchi Bai is sister-in-law (Nanand)

of deceased. It is alleged that Ramnarayan, Savitribai and Kanchanbai had an

NEUTRAL CITATION NO. 2025:MPHC-IND:29414

2 MCRC-43632-2025

altercation with deceased Parvati @ Paribai and her husband Prakash in the

evening of 10.08.2025. Thereafter, Pari Bai left her home informing her husband

that she is going to answer nature's call. Later, Pari Bai was found hanging with

the help of Sari to a tree near her house. Learned counsel contends that there was no instigation or abetment or mensrea on the part of the applicants for unfortunate suicide of Pari Bai. Learned counsel relied on the judgments in Sanju @ Sanjay Singh Sengar Vs. State of M.P. reported in AIR 2002 SC 199; Amalendu Pal @ Jhantu Vs. State of West Bengal, reported in (2010) 1 SCC 707, Arnab Manoranjan Goswami Vs. State of Maharashtra and Others reported in 2020(SCC Online) SC 964 and Abhinav Mohan Delkar Vs. State of Maharashtra reported in 2025 INSC 990 to buttress his contentions. He further submits that the final report has been submitted on completion of investigation. There is no likelihood

of tampering with evidence by the applicants for the reason that they are homemakers and are not capable to influence the witnesses. Jail incarceration on false accusation would cause hardship to the applicants and dependent family members. They are ready to cooperate in the trial.

Per contra, learned counsel for the State ably assisted by learned counsel for the objector opposes the application on the ground of gravity of alleged offence. However, after going through the case diary, he fairly states that no criminal antecedent is reported against the applicants.

According to the material available on case diary, Prakash, husband of Paribai informed P.S. Rajgarh that his wife Paribai had left home around 09.00 p.m. on 10.08.2025. She did not return home. Later, Paribai was found hanging with the help of Sari at a tree. The parents of Paribai alleged that Ramnarayan, Kanchanbai and Savitribai use to harass Paribai over domestic

NEUTRAL CITATION NO. 2025:MPHC-IND:29414

3 MCRC-43632-2025 issues and household chores. Prakssh also stated that in the evening of 10.08.2025, Ramnarayan, Savitribai and Kanchanbai had an altercation with him and his wife Paribai and they did not permit them to enter the house. On the same night, Pari Bai committed suicide by hanging. On such allegations, P.S. Rajgarh registered FIR for offence punishable under Sections 108, 85 and 3(5) of BNS, 2023. The applicant was arrested on 02.09.2025. They are in

custody ever since. The final report has been submitted on completion of investigation. Further, prima facie mere harassment without any positive proximate action on part of the accused showing mens-rea to abet the suicide does not amount to abetment for suicide or reason for death of Paribai. The contentions raised by the applicant has prima facie substance. The veracity of prosecution will be determined after evidence in the trial.

As informed, the applicants Savitri Bai and Kanchan Bai are aged around 24 years and 32 years respectively and are homemakers. They have family responsibilities. Considering these aspects, there appears to be no possibility of fleeing from justice. In absence of any criminal antecedent, considering the socio-economic status of the applicants, there appears to be no likelihood of tampering with evidence or influencing the witnesses by the applicants. There appears to be no compelling reason to continue incarceration of the applicants. However, the observations, herein-above, are recorded for present application only.

Considering the rival contentions and overall circumstances of the case, in the light of aforestated facts, but without commenting on the merits,

this Court is inclined to release the applicants on bail. Thus, the application is

NEUTRAL CITATION NO. 2025:MPHC-IND:29414

4 MCRC-43632-2025 allowed.

Accordingly, it is directed that applicants No.1 Savitri Bai @ Chandi B a i and No.2 Kanchan Bai @ Kanchi Bai shall be released on bail in connection with the Crime as mentioned in first paragraph of this order, upon furnishing a personal bond in the sum of Rs.25,000/- (Rupees Twenty Five Thousand only)each with one solvent surety each of the same amount to the satisfaction of the Trial Court, for compliance with the following conditions :

(For convenience of understanding by accused and surety, the conditions of bail are also reproduced in Hindi as under):-

(1) Applicants shall remain present on every date of hearing as may be directed by the concerned court;

(1) आवेदक संबंिधत यायालय के िनदशानुसार सुनवाई क येक ितिथ पर उप थत रहे गा । (2) Applicants shall not commit or get involved in any offence of similar nature; (2) आवेदक समान कृ ित का केाई अपराध नह ं करे गा या उसम स मिलत नह ं होगा । (3) Applicants shall not directly or indirectly make any inducement, threat or promise to any person acquainted with the facts of the case so as to dissuade them/him/her from disclosing such facts to the Court or to the police officer;

(3) आवेदक करण के त य से प रिचत कसी य को य या अ य प से लोभन, धमक या वचन नह ं दे गा, जससे ऐसा य ऐसे त य को यायालय या पुिलस अिधकार को कट करने से िनवा रत हो ।

(4) Applicants shall not directly or indirectly attempt to tamper with the evidence or allure, pressurize or threaten the witness;

(4) आवेदक य या अ य प से सा य के साथ छे डछाड करने का या सा ी या सा य को बहलाने -फुसलाने, दबाव डालने या धमकाने का यास नह ं करे गl । (5) During trial, the applicants shall ensure due compliance of provisions of Section 309 of Cr.P.C./346 of Bharatiya Nagarik Suraksha Sanhita, 2023 regarding examination of witnesses in attendance;

(5) वचारण के दौरान, उप थत गवाह से पर ण के संबंध म आवेदकगण धारा ३०९ दं. .सं. / ३४६ भारतीय नाग रक सुर ा सं हता, 2023 के ावधान का उिचत अनुपालन सुिन त करगे।

This order shall be effective till the end of trial. However, in case of breach of any of the preconditions of bail, the trial Court may consider, on merit, cancellation of bail without any impediment from this order.

The trial Court shall get these conditions reproduced on the personal bond by the accused and on surety bond by the surety concerned. If any of them is unable to write, the scribe shall certify that he/she had explained the conditions to the concerned accused or the surety.

NEUTRAL CITATION NO. 2025:MPHC-IND:29414

5 MCRC-43632-2025 C.C. as per rules.

(SANJEEV S KALGAONKAR) JUDGE

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