Delhi High Court Urges Courts To Fast-Track FIR Registration Pleas In Cases Concerning 'Unnatural Death' Of Young Bride
The Delhi High Court has expressed concern over delays in registration of FIRs in cases involving the unnatural death of young married women.
Justice Swarana Kanta Sharma urged the courts to give greater urgency to pleas seeking registration of FIRs where allegations of dowry-related harassment are raised and the police fail to act within time.
“This Court hopes that, in future, applications seeking directions for registration of FIR, concerning the unnatural death of a young woman within a short period of marriage, particularly where allegations of dowry-related harassment are raised and the police fail to register an FIR, shall be taken up with greater urgency by the Courts and be listed on shorter dates so that the issue of registration of FIR and commencement of investigation is not left unresolved for months together,” the Court said.
The Court made the observations while denying anticipatory bail to a husband and his parents in a dowry death case involving the death of a young woman within six months of marriage.
It observed that grieving parents cannot be expected to immediately recount every instance of cruelty and dowry harassment while coping with the shock of their daughter's death.
It rejected the anticipatory bail pleas of the husband, father-in-law and mother-in-law accused in an FIR registered under Sections 80 and 85 of the Bharatiya Nyaya Sanhita (BNS).
The deceased woman died in July 2025, allegedly by hanging, within a few months of her marriage. The FIR, however, came to be registered only in March this year after directions from a Magistrate.
The accused primarily argued that the deceased's parents had not levelled any detailed allegations of dowry harassment in their statements before the Executive Magistrate immediately after the death, and that the subsequent complaint containing specific allegations was an afterthought.
Rejecting the said contention, Justice Sharma observed that the law cannot demand the bereaved parents standing beside the body of their deceased daughter to provide a complete and detailed account of every incident of cruelty and harassment at that stage.
“Can a grieving parent be expected, within hours of such a loss, to give a complete detailed account of all the events which may have contributed to the unfortunate death of his or her daughter?” the Court asked.
Justice Sharma also took serious note of the delay in registration of the FIR, observing that the complainant-father had approached authorities promptly but was compelled to seek judicial intervention before the criminal law was set in motion.
“The registration of the FIR in relation to the unnatural death of a young woman took more time than the entire duration of her marriage itself,” the Court remarked.
Expressing concern over the police action, the Court said it was shocked that despite the crime scene revealing broken bangles and anklet pieces, no FIR was registered and the matter remained at the inquiry stage for months.
“Despite this, it is shocking that the Police did not even then, deem it appropriate to conclude that the case needed probe and registration of the FIR. Resultantly, the accused persons were not arrested and investigation is still to be carried out after the accused persons joined investigation, which they have not till date,” the Court said.
Considering the gravity of allegations, the fact that the death occurred within months of marriage, and that the investigation was still at a nascent stage, the Court held that custodial interrogation could not be ruled out.
It further noted that the parents of the deceased approached the authorities, made statements before the Executive Magistrate and subsequently submitted a detailed complaint to the concerned SHO but they were ultimately compelled to pursue remedies before the Court for registration of an FIR.
“The record itself reflects that the learned Magistrate found it necessary to repeatedly seek explanations regarding the manner in which the matter had been handled, and the concerned DCP informed the Court that disciplinary proceedings had been initiated against the erring police officials,” the Court said.
It added that the unfortunate reality, however, was that the father of the deceased was made to run from pillar to post only to ensure that an FIR is registered and investigation is conducted regarding the unnatural death of his young daughter.
Title: SANDEEP @ SUNNY v. STATE & other connected matters