Madhya Pradesh High Court
Satish Jaat vs The State Of Madhya Pradesh on 19 September, 2025
Author: Sanjeev S Kalgaonkar
Bench: Sanjeev S Kalgaonkar
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IN THE HIGH COURT OF MADHYA PRADESH
AT INDORE
BEFORE
HON'BLE SHRI JUSTICE SANJEEV S KALGAONKAR
ON THE 19th OF SEPTEMBER, 2025
MISC. CRIMINAL CASE No. 42503 of 2025
SATISH JAAT
Versus
THE STATE OF MADHYA PRADESH
Appearance:
Shri Sanjay Kumar Sharma - Advocate for the applicant.
Shri Apoorv Joshi GA for the State.
ORDER
1. This first bail application has been filed by applicant under
Section 483 of Bharatiya Nagarik Suraksha Sanhita 2023 for grant of
regular bail in connection with Crime No. 289 of 2025 registered at Police
Station- Neelganga, District- Ujjain (M.P.) for offence punishable under
Sections 108, 3(5) of the BNS, 2023 Applicant is in judicial custody since
01/07/2025.
2. Heard the arguments.
3. Perused the grounds for grant of bail stated in the application, case
diary and the relevant material on record.
4. Learned counsel for the applicant in addition to the grounds
mentioned in the application submits that the applicant is falsely implicated
in the alleged offence merely for the reason that the applicant Satish is
husband of deceased Nupur. Learned counsel further submits that there was
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matrimonial discord between applicant Satish and deceased Nupur. Learned
counsel referring to the judgment dated 25/10/2024 passed in RCT no.
1818/2022, submits that Nupur had lodged prosecution for offence
punishable under section 498-A of the IPC against the mother and sister of
the applicant, which ultimately resulted into acquittal. The applicant had filed
a petition for divorce against Nupur on 16/12/2024. Learned counsel
referring to the order dated 10/08/2023 (Annexure-A/9) submits that the
matter regarding divorce was ultimately amicably settled between them.
Learned counsel further referring to the material on case dairy, contends that
the applicant had left his matrimonial home three days before the death of
Nupur, due to discord between them. There was no communication between
them in close proximity of her death. No offence, as alleged, is committed by
the applicant. The final report has been submitted on completion of
investigation. Co-accused Bhawna and Hemlata have been extended benefit
of anticipatory bail by co-ordinate Bench of this Court vide order dated
14/07/2025 passed in MCRC no. 30209/2025. There is no likelihood of
tampering with evidence by the applicant. Jail incarceration is causing
hardship to the applicant and the dependent family. Applicant is ready to
cooperate in trial.
5. Per contra, learned counsel for the State opposes the application
on the ground of gravity of alleged offence. Learned counsel further refers to
one criminal antecedent as mentioned in the case diary
6. In reply, learned counsel for the applicant submits that other
matter is pending for trial. He has never been convicted.
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7. According to the material available on case diary, Nupur was
married to applicant Satish on 25/04/2021. Nupur was admitted at Awanti
Hospital by Krishna Malviya on 15/06/2025 due to consumption of some
poisonous substance. Nupur succumbed to death during treatment on the
same day. Krishna Malviya and Shradha Dubey informed that Nupur had
forwarded them one hand written note on Whatsapp, wherein she informed
had consumed poison, therefore, they immediately took Nupur to Awanti
Hospital. The hand written note forwarded on Whatsapp was recovered,
wherein Nupur had alleged that applicant Satish, his mother and sister are
harassing her. Her husband is not giving money to manage household
expenses and manhandle her. Her husband had left her at matrimonial home
and went away three days ago, therefore, she is committing suicide. On such
allegations, the PS - Neelganga, Ujjain registered FIR for offence punishable
under Sections 108, 3(5) of the BNS, 2023 against Satish (husband), Hemlata
(mother-in-law) and Bhawna (sister-in-law). The applicant was arrested on
01/07/2025. He is in custody ever since. The final report was submitted on
completion of investigation. The trial would take time to conclude. Co-
accused have been extended benefit of bail. The veracity of prosecution will
be determined after evidence in the trial. However, the material on record
shows that the applicant was not at his matrimonial home for three days
when Nupur consumed some poisonous substance. The material available on
record discloses the matrimonial discord over domestic matters between the
applicant and his wife Nupur.
8. As informed, the applicant is aged around 28 years and is
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agriculturist by profession. He has family responsibilities. Considering these
aspects, there appears to be no possibility of fleeing from justice. In absence
of substantial criminal past and previous conviction for any major offence,
considering the socio-economic status of the applicant, there appears to be
no likelihood of tampering with evidence or influencing the witnesses by the
applicant There appears to be no compelling reason to continue incarceration
of the applicant. However, the observations, herein-above, are recorded for
present application only.
9. 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 applicant on bail. Thus, the application is
allowed.
9. Accordingly, it is directed that applicant- - Satish Jaat shall be
released on bail in connection with Crime, as mentioned in first paragraph of
this order, upon furnishing a personal bond in the sum of Rs.50,000/-
(Rupees Fifty Thousand only) with one surety 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 asunder):-
(1) Applicant 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) Applicant 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) Applicant 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
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कट करने से िनवा रत हो ।
(4) Applicant shall not directly or indirectly attempt to tamper with the
evidence or allure, pressurize or threaten the witness;
(4) आवदे क 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 गा ।
(5) During trial, the applicant 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 आवेदक धारा ३०९ दं . .सं./ ३४६
भारतीय नाग रक सुर ा सं हता, 2023 के ावधान का उिचत अनुपालन सुिन त करे गा ।
10.. 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 of this order.
11. 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 had explained
the conditions to the concerned accused or the surety.
C.C. as per rules.
(SANJEEV S KALGAONKAR)
JUDGE
amol
