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Gujarat High Court Upholds Trial Court’s Acquittal in Alleged Abetment to Suicide Case Involving Burn Death of Woman: “When Medical Evidence Cannot Ascertain Suicide or Accident, Conviction Cannot Be Sustained”

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Court’s Decision

The Gujarat High Court dismissed the State’s appeal against the acquittal of two accused charged with abetment to suicide and other offences in connection with the burn death of a woman. The Court held that the prosecution failed to prove that the death was homicidal or even suicidal, noting, “The medical officer himself is not in a position to give an opinion whether the death is accidental or suicidal… the prosecution has miserably failed to prove the fact that the death of the deceased is homicidal.” Consequently, the Court refused to interfere with the trial court’s acquittal, holding that the findings were “just and proper” and not perverse.


Facts

The case arose from an incident dated 10 March 2011, where a woman, Jashuben, suffered fatal burn injuries. Her mother lodged the complaint, alleging that the accused—her daughter’s in-laws—had verbally and physically assaulted the deceased, leading to her suicide by self-immolation. The alleged motive included harassment over a personal relationship and threats by the accused.

It was alleged that the accused dragged Jashuben by the hair, broke her bangles, threatened her younger brother to leave the room, and beat her. Shortly after, Jashuben poured kerosene on herself and set herself ablaze. Neighbours and family tried to save her, but she succumbed to the injuries in the hospital. The police registered a case for offences under Sections 302, 306, 323, 504, 506(2) read with Section 114 of the Indian Penal Code.

The Sessions Court acquitted the accused, giving them the benefit of doubt. The State of Gujarat appealed against this acquittal.


Issues

  1. Whether the prosecution had proven beyond reasonable doubt that the death of the deceased was suicidal or homicidal in nature?
  2. Whether the trial court’s acquittal was perverse or required interference by the appellate court?

Petitioner’s Arguments

The State of Gujarat, through the Additional Public Prosecutor, argued that the trial court failed to appreciate the testimonies of key prosecution witnesses. It was contended that:


Respondent’s Arguments

Counsel for the respondents contended that:


Analysis of the Law

The Court relied extensively on the settled principles governing appeals against acquittals, emphasizing that:

The Court noted that the postmortem report merely stated the cause of death as burns, and the medical officer could not determine the manner of death. Without clear medical or eyewitness evidence, the charges under Section 302 (murder) and 306 (abetment to suicide) could not be sustained.


Precedent Analysis

The Court cited several precedents laying down the limits of interference in acquittal appeals:


Court’s Reasoning

The Court observed several critical gaps in the prosecution’s case:

Hence, the High Court concluded that “the findings recorded by the learned trial Court are absolutely just and proper and in recording the said findings, no illegality and infirmity has been committed.”


Conclusion

The Gujarat High Court dismissed the State’s appeal, affirming the acquittal of the accused. It held that the prosecution failed to establish that the deceased’s death was homicidal or due to abetment, and found no perversity in the trial court’s reasoning.


Implications


Cases Referred


FAQs

1. Can an acquittal be overturned in appeal if the medical evidence is inconclusive?
No. The High Court reiterated that when the medical evidence does not confirm whether death was homicidal or suicidal, it becomes difficult to sustain a conviction. The benefit of doubt must go to the accused.

2. What is the significance of the double presumption of innocence in criminal appeals?
Double presumption means an accused is presumed innocent not only under law but also after having been acquitted by a competent trial court. Appellate courts should not disturb acquittals unless the findings are manifestly erroneous.

3. When can an appellate court interfere with a trial court’s acquittal?
Only if the trial court’s findings are perverse, illegal, or based on a complete misappreciation of evidence. Mere possibility of another view is not a ground for interference.

Also Read: Chhattisgarh High Court Enhances Motor Accident Compensation: “Tribunal Erred in Mechanically Relying Only on Oral Deposition—Pleadings Clearly Indicated Victim’s Occupation and Earnings”

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