A medical opinion attributing the death of a married woman to “shock as a result of myocardial infarction” cannot, by itself, conclusively establish a natural death so as to justify quashing dowry death proceedings at the threshold, the Allahabad High Court has held.
In Nirmala Devi v. State of U.P. and Another, Application U/S 528 BNSS No. 11303 of 2026, the Court declined to quash criminal proceedings against the deceased woman’s mother-in-law, observing that whether the medical condition was purely natural or was induced or precipitated by systematic cruelty or other extreme factors was a matter requiring evidence and a full-fledged trial.
Justice Chawan Prakash delivered the judgment on September 24, 2026.
Background of the Case
The deceased, Pratibha Yadav alias Pooja, was married to the applicant’s son, Krishnakant Yadav, on May 4, 2021. On the night of February 18/19, 2025, she was found unconscious at her matrimonial home. She was initially admitted to Laxmi Hospital, Firozabad, and was subsequently shifted to Ujala Cygnus Rainbow Hospital, Agra. She died on February 25, 2025.
The post-mortem report recorded the cause of death as shock resulting from myocardial infarction. Significantly, contusions and abrasions were also noticed on her left and right shoulders during the post-mortem examination.
Following her death, a Zero FIR was registered against her husband, mother-in-law and sisters-in-law for offences relating to dowry death, cruelty and other offences under the Bharatiya Nyaya Sanhita, 2023, along with Sections 3 and 4 of the Dowry Prohibition Act, 1961.
The FIR was subsequently transferred to the police station having territorial jurisdiction and registered as Case Crime No. 109 of 2025 at Police Station Tundla, District Firozabad.
After investigation, the police filed a charge sheet on September 10, 2025.
The mother-in-law approached the Allahabad High Court under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023, seeking quashing of the charge sheet, cognizance/summoning order and the entire criminal proceedings.
Applicant’s Argument: Death Was Due to Natural Medical Causes
The principal defence raised before the High Court was founded upon the deceased’s medical condition. According to the applicant, the deceased had been admitted to hospital with complaints of pyrexia, headache and seizures. She was later referred to a higher medical centre, where an MRI of her brain reportedly revealed abnormalities leading to a suspected diagnosis of viral encephalitis.
The death summary issued by Ujala Cygnus Rainbow Hospital recorded cardiopulmonary arrest as the cause of death, with a provisional diagnosis of fever with seizures and meningitis.
The applicant emphasised that the deceased had suffered fever, chills and headaches, followed by vomiting, altered sensorium and frothing from the mouth. She was treated in the Neuro ICU and was administered antibiotics, antiepileptic medication, mannitol and symptomatic treatment. Her condition subsequently deteriorated, followed by cardiac arrest.
Most importantly, the post-mortem examination attributed the death to shock resulting from myocardial infarction.
On this basis, it was argued that the death was purely natural and resulted from medical complications. The applicant contended that there was no material showing that the death had resulted from burns, poisoning, bodily injury or any other external or unnatural cause. Therefore, according to the applicant, an essential ingredient of the offence of dowry death under Section 80 BNS, namely that the death occurred “otherwise than under normal circumstances”, was absent.
The applicant also denied demanding additional dowry or subjecting the deceased to cruelty or harassment in connection with dowry.
Reliance was placed upon decisions of the Supreme Court including Babu Bhai v. State of Gujarat, State of Gujarat v. Afroz Mohammed Hasanfatta and Haji Iqbal v. State of U.P. and Others.
Prosecution Alleged Substantial Dowry Payments and Continued Cruelty
The State and the informant opposed the application and presented a materially different factual account. It was alleged that substantial amounts had been transferred to the applicant’s personal bank account in connection with dowry demands.
According to the prosecution, a total of ₹16.25 lakh was transferred through RTGS to the applicant’s bank account, ₹6.75 lakh on March 12, 2021 and ₹9.50 lakh on July 27, 2021, from the accounts of the deceased’s father and mother.
It was further alleged that ₹7 lakh had been paid in cash at the time of the marriage, taking the alleged total dowry payment to ₹23.25 lakh.
The prosecution maintained that the alleged harassment did not end with the marriage. The deceased was allegedly subjected to persistent demands for dowry, cruelty and harassment at her matrimonial home.
According to the informant, the circumstances became such that the deceased returned to her parental home on June 22, 2024.
She returned to her matrimonial home on January 25, 2025 following requests and assurances from her in-laws in connection with her brother-in-law’s wedding.
The prosecution further alleged that on February 15, 2025, only a few days before she was found unconscious — the deceased informed her mother that she had been physically dragged and assaulted by the applicant and her sister-in-law.
She last spoke to her mother on February 18, 2025 and was thereafter found unconscious during the night of February 18/19.
Scope of High Court’s Power Under Section 528 BNSS
Before examining the allegations, the High Court reiterated the limited nature of its jurisdiction while considering a prayer for quashing criminal proceedings under Section 528 BNSS.
The inherent power can undoubtedly be exercised to prevent abuse of the process of law or secure the ends of justice. However, the power is extraordinary and must be exercised sparingly and cautiously.
The Court explained that criminal proceedings can be quashed where the allegations, even when accepted at face value, fail to disclose the commission of an offence.
However, proceedings under Section 528 BNSS cannot be converted into a trial.
The Court observed:
“At the same time, while exercising jurisdiction under Section 528 of the BNSS, this Court is not expected to undertake a meticulous examination of the evidence, assess the probative value of the material collected during the investigation, or conduct a mini-trial.”
The enquiry at this stage is limited to determining whether the allegations, read with the material available on record, disclose the essential ingredients of the alleged offences. Disputed questions requiring appreciation of evidence ordinarily belong to the trial court.
Ingredients of Dowry Death Under Section 80 BNS
The High Court then examined the statutory requirements governing dowry death. Section 80 BNS contemplates a situation where the death of a woman is caused by burns or bodily injury or “occurs otherwise than under normal circumstances” within seven years of marriage, and it is shown that soon before her death she was subjected to cruelty or harassment by her husband or his relative in connection with a demand for dowry.
The Court identified four essential ingredients:
- the woman’s death must occur within seven years of marriage;
- the death must result from burns or bodily injury, or occur otherwise than under normal circumstances;
- soon before her death, she must have been subjected to cruelty or harassment by her husband or his relative; and
- such cruelty or harassment must have been for, or in connection with, a demand for dowry.
In the present case, the death had occurred within approximately four years of marriage. The crucial controversy was whether a death medically attributed to myocardial infarction necessarily excluded the possibility that it occurred “otherwise than under normal circumstances.”
“Otherwise Than Under Normal Circumstances” Is Not Confined to Visible Injury
The High Court rejected a narrow interpretation of the expression “otherwise than under normal circumstances”. The Court observed that the phrase cannot be restricted only to cases involving visible physical injury or fatal poisoning.
Referring to Kans Raj v. State of Punjab, the Court reasoned that where a young married woman is brought to hospital with fever, seizures and myocardial infarction against the background of allegations of persistent cruelty or mental trauma, the medical diagnosis cannot automatically be treated, at the threshold, as conclusive proof of a purely natural death.
The Court observed:
“The phrase ‘otherwise than under normal circumstances’ cannot be restricted solely to visible physical injury or fatal poisoning.”
It further stated:
“The physical strain, mental torture, or a non visible poison or substance may trigger clinical conditions such as seizures, cardiogenic shock, or myocardial infarction.”
The significance of the ruling lies in this distinction: a medical cause of death and the legal circumstances surrounding that death are not necessarily identical questions.
The mere identification of myocardial infarction as the physiological cause of death therefore did not, at the quashing stage, conclusively answer whether the death occurred under “normal circumstances” within the meaning of Section 80 BNS.
Medical Evidence Required Examination at Trial
The High Court found that resolving the medical controversy would require evidence that could not appropriately be evaluated in proceedings under Section 528 BNSS.
Whether the deceased’s fever, seizures and myocardial infarction were entirely natural or were induced or precipitated by other factors required examination of doctors and medical experts.
The Court stated:
“Determining, whether the medical conditions (fever, seizures and myocardial infarction) were purely natural or induced or precipitated by systematic cruelty or other extreme factors requires examination of the treating doctors and medical experts, as well as histopathological and toxicological examination, the viscera report and direct testimony from witnesses regarding the proximity of the harassment.”
These questions, the Court held, fell within the domain of trial and could not be conclusively determined in summary proceedings for quashing.
Post-Mortem Finding of Myocardial Infarction Was Not Conclusive
The Court accordingly refused to treat the post-mortem opinion as sufficient to terminate the prosecution. It recorded the central conclusion in the following terms:
“Considering the specific allegations of dowry demand made against the applicants and the fact that the death occurred within four years of the marriage, the medical opinion indicating ‘shock as a result of myocardial infarction’ cannot, by itself, be treated as a conclusive ground for quashing the charge sheet, the cognizance order or the entire criminal proceedings at this stage.”
The Court reasoned that accepting the medical opinion as conclusive at this stage would effectively require it to determine the legitimacy of the prosecution by conducting a premature assessment of expert medical evidence.
Such an exercise would amount to a mini-trial, which is impermissible while exercising inherent jurisdiction. Importantly, the Court did not hold that myocardial infarction was proved to have been caused by cruelty. Rather, it held that the competing explanations concerning the death could not be conclusively resolved at the quashing stage.
Allegations of Cruelty Were Specific
The Court separately examined the allegations relating to cruelty under Sections 85 and 86 BNS. Section 86 encompasses, inter alia, wilful conduct likely to drive a woman to suicide or cause grave injury or danger to her life, limb or health, whether mental or physical. It also covers harassment intended to coerce a woman or a person related to her to satisfy an unlawful demand for property or valuable security.
The High Court clarified that ordinary matrimonial discord or every instance of ill-treatment would not automatically constitute statutory cruelty.
It observed:
“Not every instance of disagreement, discord or ill-treatment between spouses would, by itself, constitute ‘cruelty’ within the meaning of Section 85 of the B.N.S.”
At the same time, the Court clarified that cruelty need not invariably consist of a series of acts:
“A single act, if sufficiently grave and of the nature contemplated by the statutory definition, may also constitute cruelty.”
In the present matter, the Court found that the allegations against the applicant were specific in nature and were supported, at the prima facie stage, by statements recorded during investigation.
It therefore could not be said that no offence under the relevant BNS provisions was disclosed against the mother-in-law.
Statutory Presumption Under Section 118 Bharatiya Sakshya Adhiniyam
Another significant aspect of the judgment concerned Section 118 of the Bharatiya Sakshya Adhiniyam, 2023, which deals with the presumption as to dowry death.
The High Court observed that once the essential ingredients of dowry death are prima facie established, particularly that the woman’s death occurred within seven years of marriage and that soon before her death she was subjected to cruelty or harassment connected with a dowry demand, the statutory presumption under Section 118 comes into operation.
In the present case, the deceased had died within four years of marriage, and there were specific allegations concerning dowry demands and cruelty shortly before her death.
Whether those allegations would ultimately be proved was a matter for trial.
Medical Cause of Death Versus Legal Character of Death
The judgment draws an important distinction between the immediate medical cause of death and the legal characterisation of the circumstances in which the death occurred.
A post-mortem report may identify myocardial infarction as the physiological mechanism leading to death. But in proceedings concerning dowry death, that finding does not necessarily dispose of the statutory enquiry into whether the death occurred “otherwise than under normal circumstances”.
Where there are allegations of dowry-related cruelty shortly before death, the causal and surrounding circumstances may require consideration of medical testimony, toxicological material, witness statements and other evidence.
Consequently, the Court was unwilling to convert a medical opinion recorded in the post-mortem report into a definitive finding of natural death before such evidence had been tested.
This does not dilute the prosecution’s burden at trial. Nor does it amount to a finding that the accused committed the offences alleged. It simply means that, on the material before the High Court, the disputed medical and factual questions could not appropriately be settled through the limited jurisdiction for quashing criminal proceedings.
High Court Refuses to Conduct a Premature Trial
The Court ultimately found that the allegations concerning dowry demands, cruelty, the proximity of the alleged assault to the deceased’s medical emergency, the fact that the death occurred within four years of marriage and the medical evidence together raised mixed questions of fact and law.
Those questions required a fair trial, during which the accused would have an opportunity to cross-examine prosecution witnesses and medical experts and to adduce defence evidence in accordance with law.
The Court held that treating myocardial infarction as conclusive proof of natural death at the Section 528 BNSS stage would involve prematurely adjudicating the evidentiary merits of the prosecution case.
Accordingly, the application seeking quashing of the charge sheet, cognizance/summoning order and entire criminal proceedings was dismissed.
Conclusion
The Allahabad High Court’s decision in Nirmala Devi v. State of U.P. and Another underscores the restricted scope of judicial scrutiny at the stage of quashing criminal proceedings.
The ruling does not establish that every death caused by myocardial infarction within seven years of marriage constitutes dowry death. Rather, it holds that where specific allegations of dowry demand and cruelty exist, a post-mortem finding of myocardial infarction cannot automatically be treated as conclusive proof of a purely natural death for terminating the prosecution at the threshold.
Whether the myocardial infarction in the present case was wholly natural or whether other circumstances played a role is an evidentiary question. According to the High Court, that question must be determined after examination of medical experts, witnesses and other relevant material at trial, not through a summary adjudication under Section 528 BNSS.
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