In a recent Supreme Court dowry death judgement, the Court overturned the conviction of a husband, sister-in-law, and mother-in-law under Section 304B of the Indian Penal Code (IPC). The Court emphasised that the prosecution failed to prove the harassment or cruelty related to dowry demands. It was stated that the wife faced such harassment prior to her death.
Initially, the trial court sentenced the three to life imprisonment, and the High Court upheld this decision. However, the Supreme Court, comprising Justices Sudhanshu Dhulia and JB Pardiwala, reviewed the case and set aside the conviction. The bench referenced Rajinder Singh vs. State of Punjab (2015), highlighting the four essential conditions for dowry death under Section 304B of IPC. This includes the unnatural death of a woman within seven years of marriage, cruelty or harassment by her husband or relatives, and the link between the harassment and dowry demands.
Trial Results
Upon reviewing witness testimonies, the Court found no solid connection between the alleged cruelty and dowry demands. The prosecution relied on general statements about the treatment of the wife, but failed to link this to dowry harassment. Additionally, the trial court and High Court misapplied Section 113B of the Indian Evidence Act, 1982. This shifted the burden of proof to the accused in cases of dowry death. The Court clarified that unnatural death within seven years of marriage alone does not automatically justify a conviction under Section 304B or 498A of IPC.
Moreover, the Court reinforced that dowry death charges cannot be upheld without concrete evidence of dowry-related harassment, citing Charan Singh @ Charanjit Singh vs. State of Uttarakhand (2023).
The presumption of dowry death was dismissed, as no direct proof of dowry harassment was presented. Witnesses only made general claims, and one witness suggested that the deceased had been assaulted for unrelated reasons.
While being dismissed the dowry death charges, it upheld the husband’s conviction under Section 306 of IPC (abetment of suicide). He was also convicted under Section 498A of IPC (cruelty). He was imprisoned with a sentence of three years with a fine of Rs. 25,000 for each offense.
By following this landmark Supreme Court dowry death judgement, the legal standards for proving dowry-related cruelty and harassment were clarified.
