1 2026:CGHC:20974 NAFR HIGH COURT OF CHHATTISGARH AT BILASPUR MCRC No. 4122 of 2026 Jitendra Singh Parihar S/o Kamlesh Singh Parihar Aged About 23 Years R/o- Pura Badarwa, Police Station- Pandakhor, District- Datiya (M.P.) At Present R/o- Gopal Nagar, Street No. 03, Ram Nagar Gudiyari Raipur, District Raipur (C.G.) ... Applicant versus State Of Chhattisgarh Through Station House OfÏcer, Police Station- Gudiyari, District- Raipur (C.G.) ... Non-applicant For Applicant : Ms. Fouzia Mirza, leaned Senior Advocate appears along with Ms. Rashmi Tandon, Advocate For State/ Non-applicant : Ms. Ritika Verma, P.L. Hon'ble Shri Ramesh Sinha , Chief Justice Order on Board 05/05/2026 1. This is the first bail application filed under Section 483 of Bhartiya Nagrika Suraksha Sanhita, 2023 for grant of regular bail to the applicant who has been arrested in connection ARPAN SRIVASTAVA Digitally signed by ARPAN SRIVASTAVA Date: 2026.05.07 19:44:34 +0530 2 with Crime No.15/2026 registered at Police Station – Gudiyari, District- Raipur (C.G.) for the offence punishable under Section 80(2) of BNS 2023. 2. That, as per the prosecution case, on 15.01.2026 a Zero FIR was registered at Police Station Gudiyari, Raipur, on the oral complaint of the father of the deceased, alleging that the deceased was married to the present applicant on 21.05.2023 and was subjected to continuous cruelty, harassment and physical assault on account of dowry demand of Rs. 5 lakhs. It is alleged that the applicant persistently beat and threatened the deceased, and despite earlier intervention by the complainant and relatives, the harassment continued. On 01.11.2025, the deceased was reported to be seriously ill, and on 02.11.2025, the complainant was informed about her death under suspicious circumstances. On the basis of these allegations, the Zero FIR was subsequently transferred and registered as Crime No. 15/2026 for the offence punishable under Section 80(2) of the Bharatiya Nyay Sanhita, 2023, and investigation was initiated. 3. Learned counsel for the applicant submits that the applicant is a small vendor selling momos and his marriage with the deceased was solemnized in the year 2023, and he has been 3 falsely implicated in the present case. It is argued that the FIR has been lodged after an inordinate delay of about 75 days, reflecting mala fide intention, and that the deceased committed suicide for reasons best known to her, as she was suffering from ailments and, except for a prior incident of a slap, no cruelty is established. It is further submitted that even the injuries noted in the postmortem report are consistent with death by hanging, and no independent witness, including neighbours, has supported the prosecution case. It is also contended that the applicant had cordial relations with the deceased, is in custody since 31.03.2026, Therefore, it is prayed that the applicant may be enlarged on bail. 4. Per contra, learned counsel for the State has opposed the bail application and submits that the allegations against the applicant are grave in nature and relate to cruelty and persistent demand of Rs. 5 lakhs as dowry, which ultimately led to the unnatural death of the deceased within a short span of marriage. It is contended that prior to the incident there were frequent quarrels between the applicant and the deceased, and the applicant had also assaulted her. It is further submitted that the ante-mortem injuries found on the 4 body of the deceased indicate that she was subjected to continuous torture and harassment, which compelled her to commit suicide, though the cause of death is hanging. Learned State counsel submits that the material collected during investigation, including statements of witnesses, prima facie establishes the involvement of the applicant, and the delay in lodging the FIR has been satisfactorily explained. Hence, he is not entitled to be released on bail. 5. I have heard learned counsel for the parties and perused the case diary. 6. Considering the rival submissions of learned counsel for the parties, the nature and gravity of the allegations and the material available on record, this Court finds that the deceased died under unnatural circumstances within a short span of marriage and there are specific allegations of dowry demand and cruelty against the applicant. The ante-mortem injuries and statements of witnesses prima facie indicate continuous harassment leading to the suicide. Though the applicant is in custody since 31.03.2026, the charge-sheet has been filed and there are no previous criminal antecedents, the seriousness of the offence does not justify grant of bail at this stage. Accordingly, the application is rejected. 5 7. Accordingly, the bail application of the applicant - Jitendra Singh Parihar involved in Crime No.15/2026 registered at Police Station – Gudiyari, District- Raipur (C.G.) for the offence punishable under Section 80(2) of BNS 2023, is rejected at this stage. 8. Needless to say that the trial Court concerned is at liberty to proceed and conclude the trial expeditiously. 9. OfÏce is directed to send a certified copy of this order to the trial Court concerned for necessary information and compliance forthwith. Sd/- Sd/- (Ramesh Sinha) Chief Justice Arpan