CRM-M No. 20532 of 2026 · Punjab And Haryana High Court · 2026

been filed by petitioner, an accused in case bearing FIR No.214 dated

24.12.2025 registered against her, u/s 108 BNS (Section 80 BNS added later on) at Police Station Sadar, District Patiala (Annexure P-1). The first petition i.e. CRM-M-10700-2026 filed by the petitioner seeking similar relief had been dismissed as withdrawn from this Court vide order dated 27.02.2026 (Annexure P-6).

#2. Relevant facts necessary for disposal of this petition are being taken from para 4 of the status report dated 20.05.2026 filed by way of affidavit of Mr. Ranbir Singh, PPS, DSP (Rural), District Patiala. The same is reproduced as under:- “That the above noted FIR No.214 dated 24.12.2025 U/s 108 BNS, CRM-M-20532-2026 2 2023 was registered at Police Station Sadar Patiala against the petitioner Rashmi Singh as well as against her son Abhijeet Singh, husband Inderjeet Singh, her daughter Suparna Singh, Parambir Singh and Prabh Bath, on the basis of the statement of the complainant- Balwinder Singh, in which, he stated that his daughter Gurjit Kaur was married to Abhijit Singh on 28.09.2023 (son of the petitioner) and he performed the marriage of his daughter as per his capacity. After about 10-11 days of the marriage i.e. on 11.10.2023, his daughter had gone to England and he had borne all the expenses of sending his daughter to England, but thereafter, she had returned to India on

12.11.2023 on being pressurized by her in-laws family, but she did not give any information to the complainant and his family in this regard. The complainant further stated that on 12.03.2024 the marriage of her(deceased’s) sister-in-law Saprna Singh was finalized, then Gurjit Kaur told the complainant that her husband, mother-in-law (present petitioner), father-in-law and sister-in-law had asked her not to tell about her return from England to anybody whereas she had already come back about one month ago. The daughter of complainant also told him that her husband Abhijit Singh had taken a loan of Rs.92000/- on the credit card of the deceased and had not paid any installment of the said loan and to settle the said loan, Gurjit Kaur started doing job in British International School, Devigarh Road, Patiala in May 2024. In this regard, the complainant had tried to talk to in-laws family of his daughter at Panchayat level, on which the accused persons namely Inderjeet Singh father-in-law, Rashmi Singh mother-in-law (present petitioner), Saprna Singh sister-in-law assured to repay the said loan within one month, but they did not repay the same. Thereupon, the complainant filed an application before SSP, Patiala which was marked to Women Cell and the concerned police had made a report in favour of complainant. The complainant also stated that his daughter Gurjit Kaur had been residing in the rented accommodation from past 06 months and on 24.12.2025, the complainant received an information that Gurjit Kaur has committed suicide by hanging herself with a ceiling fan. Upon which, the complainant along with his wife and son Davinder Singh reached the rented house and saw that body of Gurjit Kaur was hanging from fan with a dupatta and there was suicide note in the said room and in the suicide note it was written that Paramveer Singh and Prabh Bath, who were friends of Abhijit Singh CRM-M-20532-2026 3 were also harassing Gurjit Kaur. The information was given to police and consequently the FIR was registered. Copy of the suicide note is attached herewith as Annexure R-1.”

#3. Petitioner-accused, who was arrested on 28.12.2025, moved an application for grant of bail before the learned Add. Sessions Judge, Patiala. The same came to be dismissed on 29.01.2026. Aggrieved of the which, present petition has been filed.

#4. Learned counsel for the petitioner contends that petitioner, aged about 71 years old lady (mother-in-law of the deceased), has been falsely implicated in the present case as would be evident from bare perusal of the FIR, lodged at the instance of father of deceased, who pointed therein that his daughter, aged about 31 years, was married to Abhijeet Singh (son of the petitioner) on 28.09.2023 in accordance with Sikh rites and ceremonies. All the wedding expenses were borne by him. 10-11 days after the wedding, further as per the complainant, his daughter went to England and the entire expenses of the trip were incurred by him. Only on account of the pressure exerted by her in-laws, the deceased returned back to India. However, she did not inform her father (c) and started staying in a rented accommodation. It was only when the wedding of the daughter of petitioner (sister-in-law of the deceased) was solemnized in March, 2024, that he came to know the fact that the girl had since returned to India, who also allegedly narrated that her in- laws, including the present petitioner, had been harassing her. Complainant also alleged that his son-in-law, i.e. the husband of the deceased, had taken a loan on the credit card of the deceased but had failed to repay the same, as a consequence of which the deceased was facing financial crunch and was compelled to take up a job in a school in May, 2024. Various Panchayats convened to amicably resolve the dispute did not bear any positive result. CRM-M-20532-2026 4 From the contents of the FIR, it is thus, apparent that for approximately six months prior to the tragic incident, the deceased had been residing in rented accommodation after she was allegedly ousted from the matrimonial home. The petitioner and deceased stayed in the matrimonial home, no complaint was lodged by the deceased with regard to misconduct of petitioner, rather she (deceased) for reasons best known did not even intimate her father that she has returned back to India. It is further the submission of learned counsel that only vague, general and omnibus allegations have been levelled. There is nothing on record from where it can be inferred that petitioner committed any positive overt-act, soon before the incident, which instigated deceased and brought her (deceased) to such a situation in life, where she had no option but to commit suicide. It is the submission of the learned counsel that the deceased was a short-tempered person who, in the past as well, had blackmailed her husband to take her to the United Kingdom and had also threatened to commit suicide, if her wish was not fulfilled. At that stage as well, on account of the intervention made by petitioner, the deceased agreed not to take any drastic step and in this regard also issued an undertaking. Copy of the same appended along with the petition as Annexure P-5 was also executed by her admitting to her follies and assured that she would not repeat such acts in future. It is further the submission of learned counsel that husband of the deceased (son of the petitioner) tried to iron out the differences between him and his wife and made all possible efforts to save his marriage. But when his repeated requests made to the deceased did not yield any positive result, he was constrained to file a petition u/s 9 of the Hindu Marriage Act seeking restitution of conjugal rights. It is, thus, the submission of learned counsel that a plain reading CRM-M-20532-2026 5 of the ‘Suicide Note’ reveals that primary dispute stems out of the alleged non- payment of the credit card loan of Rs.92,000/- by the son of the present petitioner. The deceased had to repay the loan and, thus, alleged that her husband, his friends, (one of whom was found innocent by the police) and the family members had played a ‘fraud’ upon her. Being the old aged mother-in- law of the deceased, petitioner had no role to play in the alleged matrimonial discord between her son and deceased but only with a view to harass the entire family she (P) was unnecessarily arrayed as an accused. Towards the end, learned counsel contends that in the wake of the challan having been filed, petitioner a woman aged about 71 years, who has been in custody since 28.12.2025, deserves a lenient view to be taken in her favour, for her further incarceration would not serve any useful purpose, as the same would be violative of her fundamental rights guaranteed under Article 21 of the Constitution of India. Prayer for allowing the petition has been made.

#5. Per contra, while opposing the request for grant of bail, learned State counsel accompanied by the counsel for the complainant contended that deceased was repeatedly harassed by the petitioner. Her role highlighted in the status report has also been referred to by him. It is next the contention of learned counsel that in the wake of the deceased having penned down a ‘Suicide Note’ levelling specific allegations that her husband and his family members played a fraud on her, harassed her and brought her to such a situation in her life, where she had no option but to commit suicide, no case for grant of bail is made out. Dismissal of the petition has been prayed for.

#6. I have heard the learned counsel for the parties and with their able assistance, perused the record available on record. CRM-M-20532-2026 6

#7. It is settled that grant or refusal of bail is the discretion of the Court. Factors to be kept in mind while granting the concession of bail have been discussed by the Hon’ble Supreme Court in several cases. The essence being that while exercising powers under Section 439 Cr.P.C. (Pari materia to Section 483 of BNSS), the Court has to take into consideration various para meters including the nature of the charge, evidence, seriousness and gravity of offence, punishments to be awarded to a person, if he is convicted, his past antecedents etc. Thus, there can be no straight jacket formula for exercising the discretion and each case has to be examined on its peculiar facts. It would also be pertinent to mention here that petitioner is a lady aged about 71 years and hence, her bail petition is required to be considered, with some latitude, in terms of Section 437 of Cr.P.C. (now Section 480 BNSS) In this regard, it would be apposite to refer herein to a judgment passed by this Court on 14.03.2024 in CRM-M-11503-2024 titled as ‘Ravinder Kaur Vs. State of Punjab’ (dealing with proviso to Section 437 Cr.P.C.), relevant thereof reads as under: “It would be apposite to refer herein to the dicta of a judgment of the Hon'ble Supreme Court in a case of ‘Satender Kumar Antil Vs. Central Bureau of Investigation & Anr., 2022(10) SCC 51’, which held as under: 51. Proviso to Section 437 of the Code mandates that when the accused is under the age of sixteen years, sick or infirm or being a woman, is something which is required to be taken note of. Obviously, the court has to satisfy itself that the accused person is sick or infirm. In a case pertaining to women, the court is expected to show some sensitivity. We have already taken note of the fact that many women who commit cognizable offenses are poor and illiterate. In many cases, upon being young they have children to take care of, and there are many instances when the children are to live in prisons. The statistics would show that more than 1000 children are living in prisons along with their mothers. This is an aspect that the courts are expected to take note of as it would not only involve the interest of the accused, but also the children who are not expected to get exposed to the prisons. There is a grave danger of their being inherited not only with poverty but with crime as well.

#58. Section 437 of the Code empowers the Magistrate to deal with all the offenses while considering an application for bail with the exception of an offense punishable either with life imprisonment or CRM-M-20532-2026 7 death triable exclusively by the Court of Sessions. The first proviso facilitates a court to conditionally release on bail an accused if he is under the age of 16 years or is a woman or is sick or infirm, as discussed earlier. This being a welfare legislation, though introduced by way of a proviso, has to be applied while considering release on bail either by the Court of Sessions or the High Court, as the case may be. The power under Section 439 of the Code is exercised against an order rejecting an application for bail and against an offence exclusively decided by the Court of Sessions. There cannot be a divided application of proviso to Section 437, while exercising the power under Section 439. While dealing with a welfare legislation, a purposive interpretation giving the benefit to the needy person being the intendment is the role required to be played by the court. We do not wish to state that this proviso has to be considered favourably in all cases as the application depends upon the facts and circumstances contained therein. What is required is the consideration per se by the court of this proviso among other factors.’

#8. In view of the settled proposition of law, without dwelling deep into the merits of the case, lest it may prejudice the trial, this Court is of the opinion that petitioner, whose past antecedents are clean and who has been in custody since 28.12.2025, deserves to be extended the concession of bail as the likelihood of completion of trial is quite remote, for none of prosecution witnesses have been examined. Thus, when viewed in this light, further incarceration would not only be violative of her rights under Article 21 of the Constitution of India, including right to speedy trial. Resultantly, petitioner is granted the concession of bail subject to her furnishing bail/surety to the satisfaction of the learned Duty Magistrate/trial Court concerned. The petitioner shall abide by the following conditions:- (i) The petitioner shall not leave the country without prior permission of the trial Court and shall deposit the passport in the trial Court. (ii) The petitioner will not tamper with the evidence during the trial. (iii) The petitioner will not pressurize/ intimidate the prosecution witnesses. (iv) The petitioner will appear before the trial Court on each and every date fixed, unless is exempted by a specific order of Court. CRM-M-20532-2026 8 (v) The petitioner shall not commit an offence similar to the offence of which, she is an accused, or for commission of which he is suspected of. (vi) The petitioner shall not directly or indirectly coerce, induce, threaten or promise to any person acquainted with the facts of the case so as to dissuade him/her from disclosing such facts to the Court or to any police officer or tamper with the evidence in any manner. (vii) The petitioner shall not in any manner misuse his liberty. (viii) The petitioner shall furnish her address and mobile number to the Trial Court forthwith and shall not change the same till the conclusion of the trial and in case for any reason, the petitioner seeks to change any of the aforesaid, the same shall be done only with prior intimation to the learned Trial Court, stating the reason for the same. (ix) The trial Court/Duty Magistrate may impose any other condition, as deemed appropriate while releasing the petitioner. Accordingly, the present petition is allowed and it is made clear that in case there is any breach of the aforesaid conditions, the State shall be at liberty to seek cancellation of bail as granted to the petitioner by this order. In view of the above, it is clarified that the observations made herein are limited for the purpose of present proceedings and would not be construed as an opinion on the merits of the case and the trial would proceed independently of the aforesaid observations.

16.07.2026 Parveen kumar (AARADHNA SAWHNEY) JUDGE Whether speaking/reasoned :Yes/No :Yes/No Whether reportable