Supreme Court Gives Bail To The Dentist In Wife’s Mysterious Death Within 4 Months of Marriage
In a dramatic turn in a high-profile matrimonial death case, the Supreme Court on January 23, 2026 granted bail to a Bhopal-based dentist accused in the death of his doctor wife just four months after their wedding, noting that dowry allegations were not part of the initial complaint and that he has been behind bars since March 2025.
A bench of Justices Prashant Kumar Mishra and N V Anjaria allowed an appeal filed by Abhijit Pandey against Madhya Pradesh High Court's judgment of October 6, 2025 which has rejected his bail plea filed under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023 in connection with the FIR registered at Police Station – Shahpura, District – Bhopal, Madhya Pradesh, for the offence punishable under Section 108 of the Bharatiya Nyaya Sanhita, 2023.
A charge-sheet was filed for the offences punishable under Sections 108 and 80 of the BNS and Sections 3 and 4 of the Dowry Prohibition Act.
A special judge framed charges under Sections 108 and 80(2) of the BNS and, in the alternative, under Sections 103 and 85 of the BNS and Sections 3 and 4 of the Dowry Prohibition Act.
The appellant, a dentist, was running a clinic at MP Nagar, Bhopal, where he came in contact with the deceased-Dr Richa Pandey. After one and a half years of relationship, they got married on December 04, 2024 and started their matrimonial life while residing at House in Bhopal. The deceased died on March 21, 2025 which was initially termed as suicide.
The High Court rejected the appellant's petition for regular bail by looking at the overall facts and circumstances of the case and seriousness of offence.
His counsel submitted, the present case is an unfortunate case of commission of suicide by the deceased as she was suspecting an extra-marital relation of the appellant with one woman, who was working in his clinic.
He submitted that there is absolutely no material which would amount to abetment of committing suicide. There was no material either to prima facie conclude that the appellant is guilty of committing murder or dowry death of the deceased.
He said that in the FIR and in the initial case diary statements of the witnesses, there was no allegation of demand of money/dowry, which has come in the subsequent statements of the said witnesses by way of improvement. It was contended that the appellant, who is a dentist by profession, is not a hardened criminal; therefore, once the charge-sheet has been filed, there was no justification for keeping him inside the jail.
The counsel for respondents State and the complainant opposed the plea, saying, the present is a case of committing murder of the deceased by injecting Atracurium Besylate Injection.
They submitted that when the post-mortem was conducted, five injuries were found which suggest commission of physical assault on the deceased before death. It was claimed that the statements of Renu Pandey (mother of the deceased), Vinod Chandra Pandey (father of the deceased), Himanshu Pandey (brother of the deceased), Prakash Chandra Pandey (uncle of the deceased) and other relatives clearly demonstrate that the appellant used to demand money from the deceased and, thus, a prima facie case of dowry death was made out.
In a counter affidavit, it was claimed on the intervening night of March 20-21, 2025 in which she had sent the PIN number of her mobile phone. When the deceased’s Apple iPhone was opened through that PIN, the Police recovered a photograph of a two-page handwritten suicide note, several WhatsApp chats, screenshots and an audio recording of a quarrel between the deceased and the accused on the night.
In this recording, the deceased can be heard stating that “You only give importance to Mahi, (another woman). You do everything for her, You don’t do anything for me. You will see my dead face tomorrow morning”. These contents disclosed persistent marital discord and emotional distress.
According to the post-mortem report, the court noted that injury no.(iv) is within four to five days prior to death. Injury nos.(i), (ii) and (iii) were probably caused by the needle of syringe/injection. As far as injury no.(v) is concerned, the post-mortem report does not indicate about how the injury was caused and the probable time between the injury and death.
The court also found that the FIR was registered for an offence relating to abetment to commit suicide. No allegation of demand of dowry was made. Further, the allegation concerning demand of money/dowry came in the subsequent case diary statements.
The bench thus said, it was inclined to allow the present appeal and release the appellant on bail, considering that the FIR was registered for an offence concerning abetment to commit suicide and the deceased had not sustained any such injury which can be said to be the cause of her death.
The bench also noted prima facie it is found that she died of Atracurium Besylate Injection which is a medicine given as anaesthesia and the deceased herself was an anaesthetist and that the allegation of demand of money/dowry was not made in the first instance but was made in the subsequent case diary statements.
The court also took into account the reason that the appellant is not a hardened criminal, though one more case is registered against him concerning cheating and forgery in which a large number of persons are involved and there being no possibility of the appellant not being available for trial as also for the reason that he is in jail since March 25, 2025.
Setting aside the High Court's order, the court clarified that none of the observations made herein would have a bearing on the main trial.
Case Title Abhijit Pandey Vs The State of Madhya Pradesh And Another
Bench: Justice Prashant Kumar Mishra and Justice N V Anjaria
Date of Order: January 23, 2026