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Madhya Pradesh High Court
Sakun Baiga vs The State Of Madhya Pradesh on 11 February, 2026
NEUTRAL CITATION NO. 2026:MPHC-JBP:11978
1 MCRC-55096-2025
IN THE HIGH COURT OF MADHYA PRADESH
AT JABALPUR
BEFORE
HON'BLE SHRI JUSTICE DEVNARAYAN MISHRA
ON THE 11th OF FEBRUARY, 2026
MISC. CRIMINAL CASE No. 55096 of 2025
SAKUN BAIGA
Versus
THE STATE OF MADHYA PRADESH
Appearance:
Ms. Ruth - Advocate for applicant.
Mr. Atmaram Bain - Deputy Government Advocate for State.
ORDER
This is the first application filed by the applicant under Section 483
of Bharatiya Nagarik Suraksha Sanhita, 2023, for grant of regular bail
relating to FIR/Crime No.451 of 2025 registered at Police Station-Umaria,
District-Umaria (M.P.) for the offence punishable under Sections
85, 80(2) of the Bharatiya Nyaya Sanhita, 2023 and under Sections 3, 4 of
the Dowry Prohibition Act. The applicant is in jail since 06.10.2025.
2. Learned counsel for the applicant submits that the applicant is the
mother-in-law of the deceased Pooja Baiga. It is alleged that the applicant
demanded a sum of Rs. 50,000/- for the construction of a pucca house.
Learned counsel further contends that even if such demand is presumed, the
same cannot be construed as a demand for dowry, as it was allegedly made
in the capacity of a relative. It is further submitted that the applicant has not
subjected the deceased to any form of harassment or cruelty. Hence, no
NEUTRAL CITATION NO. 2026:MPHC-JBP:11978
2 MCRC-55096-2025
prima facie case is made out against the applicant. It is, therefore, prayed that
the applicant be enlarged on bail.
3. Learned counsel for the respondent/State has opposed the bail
application, submitting that the applicant and his son Amar were demanding
a sum of Rs. 50,000/- from the deceased's family for the purchase of a
motorcycle. It is contended that pursuant to such demand, the parents of the
deceased paid an amount of Rs. 20,000/-. Thereafter, upon purchase of the
motorcycle by co-accused Amar, the applicant and his son Amar allegedly
renewed their demand for an additional sum of Rs. 50,000/- for construction
of a pucca house. It is further submitted that when the family members of the
deceased expressed their inability to fulfill the said demand immediately,
stating that they would arrange the amount as per their financial capacity and
the deceased was subjected to mental harassment, which ultimately led her to
commit suicide by hanging. In view of the aforesaid allegations and the
gravity of the offence, learned counsel for the State submits that no case for
grant of bail is made out in favour of the applicant.
4. Heard the parties and perused the case diary.
5. Looking to the aforesaid factual aspects of the case, it is apparent
that the marriage between the deceased and her husband Amar, was
solemnized on 01.05.2021. The deceased committed suicide on 12.09.2025.
As per the recitals contained in the FIR, it is evident that the husband and the
deceased were residing separately from the husband's parents i.e the
applicant in a different house. On 12.09.2025, a dispute is stated to have
taken place between the husband and the deceased concerning a mobile
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3 MCRC-55096-2025
phone. It has further been alleged that on the said date, the husband did not
sleep in the house where the deceased was staying, but instead stayed at his
parents' house. On the following morning, the deceased, namely Pooja
Baiga, was found dead, having committed suicide by hanging. No specific
role has been assigned to this applicant and trial will take time to be
concluded, this Court deems it appropriate to enlarge the applicant on bail.
Thus, without commenting anything on the merits of the case, the application
is allowed.
6. It is directed that applicant shall be released on bail on her
furnishing a personal bond in the sum of Rs.50,000/- (Rupees Fifty
Thousand Only) with one solvent surety of the like amount to the satisfaction
of the trial Court concerned for her appearance before the said Court on all
such dates as may be fixed by that Court in this regard during pendency of
trial.
7. It is further directed that the applicant shall comply with the
provisions of Section 480(3) of BNSS.
8. Accordingly, Misc. Criminal Case stands disposed of.
Certified copy as per rules.
(DEVNARAYAN MISHRA)
JUDGE
julie
