New Delhi: My first brush with Satya-ji, or Satyarani Chadha, was at the tony India Habitat Centre here in the nation’s capital. My senior, Indira Jaising, under the banner of her NGO, the Lawyers Collective, had organised a “Colloquium” where constitutional court judges and international jurists were invited to present scholarly papers on domestic violence.

Suddenly, there was a flutter. 

Satya-ji had landed up with a group of women survivors of domestic violence and insisted on being allowed to speak. As the event was in English and conceived as a jurisprudential intervention, the very consumers of the law were silenced. 

Satya-ji was placated with the promise that her day would come.

That meeting was in May 1999. Her day finally came in 2013—14 years after the Colloquium, and 34 years since Satya-ji’s daughter Kanchan Bala, or Sashi, was burned to death because her poor family could not meet a demand for a scooter from the groom.

“Dowry death” is the subcontinent’s indigenous contribution to global violence against women—a unique phenomenon where brides are killed because their families cannot meet financial or material demands from the groom’s side.

An organisation in Bengaluru, Vimochana, once surveyed Indian kitchens and found a peculiar phenomenon: stoves exploded only on daughters-in-law, never on mothers-in-law.

Satya-ji’s quest for justice soon catapulted her into becoming the mascot for law reform on dowry.

A Law With Ancient Roots

British India never outlawed dowry. If it had, perhaps India would have been deprived of her financial capital, for Bombay itself came to the British in dowry with the Portuguese princess Catherine De Braganza, who married England’s King Charles II.

The first attempt came with the Sind Deti Leti Act, 1939. Later, the introduction of the Dowry Prohibition Act, 1961, acknowledged that since Vedic times—even according to the Dharmashastra—the act of Kanyadaan was incomplete until the bridegroom received a Dakshina. What began as voluntary, over time turned coercive.

Even the Hindu treatise often criticised for its male centricity, the Manu Smriti, stipulates: “Strīdhanāni tu ye mohādupajīvanti bāndhavāḥ | nārīyānāni vastraṃ vā te pāpā yāntyadhogatim (Those relations who, through folly, live upon the bride’s properties—even the bride’s conveyances and clothes—are sinners and fall into the lowest state.)”

But when Kanchan lost her life, Satya-ji discovered firsthand the inadequacies of the law. At the time, punishment was limited to six months imprisonment. Burdened with numerous other duties, government officials were also made Dowry Prohibition Officers. 

Social norms, a moribund criminal justice system, and fear of stirring the hornet’s nest made convictions nearly impossible.

The Birth of a Movement

Patriarchy spared no faith. Satya-ji found a comrade in Shah Jahan, who too had lost her daughter, Noor Jahan, to dowry. For India, the life of young Sashibala was worth less than a scooter, but Satya-ji was determined that no other daughter would suffer the same fate.

Together, Satya-ji and Shah Jahan launched a nationwide agitation against dowry deaths and bride burning. An iconic photograph of Satyarani sitting on the steps of the Supreme Court with Sashi’s picture became a national clarion call for action.

Action followed. The law was tightened: punishment for taking dowry rose from six months to five years, and even a mere demand became punishable with two years imprisonment. 

Section 4A was inserted into the Dowry Prohibition Act, prescribing five years’ punishment for advertising dowry. Bride burning was made a specific offence (section 304B, Indian Penal Code 1960. Even the Evidence Act, 1872, was amended, reversing the burden of proof in cases where a bride died unnaturally within seven years of marriage. 

The groom now had to prove the death was not dowry-related. Matrimonial cruelty too became a specific offence.

Victory, But Not For Herself

Satya-ji and Shah Jahan also founded Shakti Shalini, which rescued and rehabilitated hundreds of women through a short-stay home and skill training. Yet Satya-ji gradually realised that the more things changed, the more they remained the same.

Her personal battle for justice dragged on. She commuted daily by bus to Jangpura, where Shakti Shalini was based, but her daughter’s case languished. The criminal law reforms she had helped secure could not be retrospectively applied. 

With Indira Jaising’s intervention, prosecutorial support was arranged. On 10 May 2000, her son-in-law Subash Chandra was sentenced to seven years’ imprisonment for abetment of suicide.

The courts gradually began interpreting dowry law as a weapon against social evil. Demands for money could be held as dowry even if made immediately after marriage, provided a nexus was established.

In 2013, I argued on Satya-ji’s behalf when Subash’s appeal came before Justice Indermeet Kaur in the Delhi High Court. Subash, now remarried with children, mounted an expensive defence led by senior advocate Dinesh Mathur. 

He objected to my presence, saying I had no locus since the State was the respondent. Justice Kaur brushed it aside. 

I told the court: “The mother of the deceased has fought for her daughter from the steps of the Supreme Court and compelled the State to reform the law of dowry and cruelty. It is a tragedy that she is still waiting for justice for her own daughter.”

Belated, Hollow Justice

Justice Kaur dismissed Subash’s appeal. By then, however, it was too late. Satya-ji, ousted through palace intrigue from Shakti Shalini, was at home battling early cancer and dementia. 

When Indira Jaising brought her the High Court’s order, Satya-ji was in no state to savour her hard-fought success. Adding to the tragedy, Subash absconded and has never served a single day in prison.

Although data from the 1980s is scarce, scholar Peter Mayer estimated dowry-related deaths at around 3,000 in 1989, with numbers gradually rising thereafter. 

Since 1995, yearly deaths have hovered around 7,000. The Press Information Bureau reported 7,167, 7,141 and 6,966 dowry deaths in 2018, 2019 and 2020, respectively. The National Crime Records Bureau documented 6,450 deaths in 2022—a slight decline from 6,753 in 2021 and 6,966 in 2020.

An Unfinished Struggle

Satya-ji passed away on 1 July 2014, joining her Sashibala. The women’s movement she left behind has faced difficult times. 

Over the past decade, social space has shrunk, people’s movements have been pushed back, and leaders have faced a backlash. The voices of women on the streets have grown faint, drowned out by anchors in studios and trolls on social media.

In recent years, even courts have suggested that laws to protect women are being “abused” (here and here). 

While evidence for this is largely anecdotal, cases such as Atul Subhash’s pre-suicide statement alleging harassment by his wife, or the sensational killing of Indore’s Raja Raghuvanshi by his bride while on a Meghalaya honeymoon in May 2024, have only fuelled this narrative.

Yet the gruesome bride burning of Nikki Bhati in Noida in August 2025 has reminded India that Satya-ji’s dream of an India free of dowry violence remains unfulfilled.

(Sanjoy Ghose is a senior advocate practising in the Supreme Court and Delhi High Court.)

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