Supreme Court Acquits Man in Dowry Death Case: “Trial Courts Must Avoid Moral Convictions and Ensure Prosecution Proves Cruelty Soon Before Death” – Holds That Contradictory Witness Statements and Lack of Evidence Cannot Justify Conviction Under Section 304-B IPC

Court’s Decision

The Supreme Court set aside the conviction of the appellant under Sections 304-B (Dowry Death) and 498-A (Cruelty to Wife) of the IPC, ruling that the prosecution failed to establish the essential legal ingredients of the offences beyond a reasonable doubt.

The Court observed that:

1. There was no concrete evidence to prove that the deceased was subjected to cruelty or harassment for dowry “soon before her death”, a key requirement for conviction under Section 304-B IPC.
2. The prosecution’s case contained several contradictions and omissions, which cast doubt on its reliability.
3. The legal presumption under Section 113-B of the Indian Evidence Act, which shifts the burden of proof to the accused in dowry death cases, could not be applied because the essential ingredients of Section 304-B were not satisfied.
4. Trial courts need to be careful in such cases and not convict based on assumptions or moral beliefs rather than strict legal principles.

As a result, the appellant was acquitted, and his bail bonds were canceled.

Facts

1. Marriage and Allegations of Dowry Demands
   • The appellant married the deceased on June 25, 1996.
   • The prosecution alleged that after the marriage, the appellant and his family harassed the deceased for dowry.
   • Demands included a colour television, motorcycle, refrigerator, mixi, new furniture, and ₹60,000 for a jeep.
2. Suicide of the Deceased
   • On April 2, 1998, the deceased was found hanging, and the postmortem confirmed asphyxia due to hanging.
   • Her mother (PW-6), brother (PW-7), and maternal uncle (PW-8) testified that she was harassed for dowry.
3. Criminal Proceedings
   • The Sessions Court convicted the appellant under Sections 304-B IPC (dowry death) and 498-A IPC (cruelty) and sentenced him to:
     • 7 years rigorous imprisonment under Section 304-B IPC.
     • 1 year imprisonment under Section 498-A IPC.
     • A fine of ₹500, with a default sentence of 3 months.
   • The High Court upheld the conviction.
4. Supreme Court Appeal
   • The appellant challenged his conviction, arguing that:
     • The prosecution failed to prove that he harassed the deceased for dowry soon before her death.
     • There were significant contradictions and omissions in witness testimonies.
     • The conviction was based on assumptions rather than legal proof.

Issues Before the Supreme Court

1. Did the prosecution prove beyond a reasonable doubt that the deceased was subjected to cruelty or harassment for dowry soon before her death?
2. Was the presumption under Section 113-B of the Indian Evidence Act applicable in this case?
3. Did contradictions and omissions in the prosecution’s evidence weaken its case?

Petitioner’s Arguments

1. No Proof of Dowry Harassment Soon Before Death:
   • The key requirement under Section 304-B IPC is that the deceased must have been harassed for dowry soon before her death.
   • The prosecution failed to prove any such harassment close to the time of death.
2. Contradictions and Omissions in Witness Testimonies:
   • PW-6 (mother of the deceased) mentioned several dowry demands in court, but these were missing from her initial police statements.
   • PW-7 (brother of the deceased) similarly made new claims in court which were absent from his earlier statements.
   • PW-8 (maternal uncle) had no direct knowledge of harassment.
3. Delayed Statements Were an Afterthought:
   • Many allegations regarding dowry demands were made months after the death, casting doubt on their credibility.
4. Supreme Court Precedent Supports Acquittal:
   • The appellant cited Charan Singh alias Charanjit Singh v. State of Uttarakhand (2023 SCC OnLine SC 454), where the Supreme Court held that vague dowry allegations are insufficient for conviction under Section 304-B IPC.

Respondent’s Arguments

1. There Was Evidence of Dowry Harassment:
   • PW-6 and PW-7 testified that nine to ten days before her death, the deceased informed them that the appellant demanded ₹60,000 for a jeep.
   • The appellant personally made this demand to PW-6 and PW-7.
2. Presumption Under Section 113-B Applies:
   • Since there was evidence of a dowry demand close to the deceased’s death, the Court should presume the appellant guilty under Section 113-B of the Evidence Act.

Analysis of the Law

1. Ingredients of Section 304-B IPC (Dowry Death)
   • A woman must have died an unnatural death (suicide in this case).
   • The death must have occurred within seven years of marriage.
   • She must have been harassed for dowry soon before her death.
   • The harassment must be in connection with a dowry demand.
2. Legal Presumption Under Section 113-B of the Evidence Act
   • If the prosecution proves dowry harassment soon before death, the Court presumes the accused caused the dowry death.
   • However, if there is no evidence of cruelty close to the time of death, the presumption cannot apply.

Precedent Analysis

• The Court relied on Charan Singh alias Charanjit Singh v. State of Uttarakhand (2023 SCC OnLine SC 454), where it ruled that mere allegations of dowry harassment are insufficient unless supported by clear evidence.
• The prosecution must prove cruelty or harassment soon before the woman’s death.

Court’s Reasoning

1. Witness Testimonies Contained Major Contradictions:
   • PW-6’s statements about dowry demands were absent in her first two police statements.
   • PW-7’s claims about the appellant physically assaulting the deceased were vague and lacked supporting evidence.
   • PW-8 had no direct knowledge of dowry harassment.
2. No Evidence of Harassment Soon Before Death:
   • The deceased had not complained of cruelty or harassment immediately before her death.
   • The prosecution failed to prove a clear connection between the alleged dowry demands and the suicide.
3. Misapplication of Section 113-B Presumption:
   • Since harassment close to the time of death was not proven, the presumption under Section 113-B did not apply.
4. Criticism of Trial Courts’ Approach:
   • The Court criticized trial courts for convicting accused persons based on moral grounds rather than legal principles.
   • It urged State Judicial Academies to train judges on properly interpreting Section 304-B IPC.

Conclusion

1. The prosecution failed to prove beyond reasonable doubt that the appellant harassed the deceased for dowry soon before her death.
2. The conviction under Sections 304-B and 498-A IPC was quashed.
3. The appellant was acquitted, and his bail bonds were canceled.
4. The Court emphasized that trial courts must base convictions on legal evidence, not assumptions.

Implications

1. Strict Application of Dowry Death Laws:
   • Courts cannot convict accused persons under Section 304-B IPC unless all legal ingredients are satisfied.
2. Judicial Training on Dowry Death Cases:
   • The Court called for better training of trial judges on handling dowry death cases.
3. Higher Standard of Proof for Prosecution:
   • Prosecutors must present clear, consistent evidence to prove dowry harassment soon before the woman’s death.

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