Dowry Death: Supreme Court acquits husband due to lack of evidence on dowry demand in Criminal Appeal No.112/2014 (11 February 2025)

Introduction

Date of the Judgment: 11 February 2025

Judges: B.R. Gavai, J. and K. Vinod Chandran, J.

Can a conviction under Section 304B of the Indian Penal Code, 1860 stand when the essential ingredient of dowry demand is not sufficiently proven? The Supreme Court addressed this critical question in a recent case involving a husband accused of dowry death after his wife was found dead within six months of marriage. The court emphasized the need for caution in dowry death cases, especially when allegations may arise from the despair and discord following an abrupt death in the matrimonial home. Justices B.R. Gavai and K. Vinod Chandran, constituting the bench, delivered the judgment.

Case Background

The case involves a young bride who was found hanging in her matrimonial home within six months of her marriage. Her father and brother discovered her body upon arriving at the residence she shared with her husband. A First Information Report (F.I.R.) was filed, leading to the arrest of the husband, who is the respondent in this appeal. Subsequently, the husband’s relatives, including his parents, grandfather, and brother, were also implicated as accused in the case.

Timeline:

Course of Proceedings

The Trial Court acquitted all the family members of the husband but convicted the husband, primarily based on unexplained scratches found on the deceased’s body. The court presumed these scratches indicated torture related to unfulfilled dowry demands, leading to the application of the presumption under Section 113B of the Evidence Act. The husband was sentenced to seven years of Rigorous Imprisonment (R.I.) under Section 304B of the I.P.C.

The High Court, upon reviewing the evidence, particularly the testimonies of the brother and father of the deceased, found it improbable that a demand for ₹4,00,000/- and a plot of land was made, considering the parties’ financial and social status. Consequently, the High Court concluded that the prosecution failed to prove the dowry demand led to the death of the deceased.

Legal Framework

Section 304B, Indian Penal Code, 1860: This section addresses dowry death, stating that if a woman dies within seven years of her marriage due to burns or bodily injury, or under suspicious circumstances, and it is shown that she was subjected to harassment for dowry demands by her husband or any relative, her death is considered a dowry death. The punishment is a minimum of seven years imprisonment, which may extend to life imprisonment.

Section 113B, Indian Evidence Act, 1872: This section provides a presumption regarding dowry death. If it is proven that, shortly before her death, the woman was subjected to cruelty or harassment for dowry demands, the court shall presume that such a person caused the dowry death.

Arguments

• Appellant (State): The State argued that the Trial Court’s conviction was justified because the scratches on the deceased’s body indicated physical violence, corroborating the allegations of dowry-related harassment. The prosecution contended that the circumstances of the death, occurring shortly after marriage, coupled with the alleged dowry demand, should invoke the presumption under Section 113B of the Evidence Act.
• Respondent (Husband): The defense argued that the prosecution failed to provide concrete evidence of dowry demands. The respondent highlighted inconsistencies and omissions in the testimonies of the deceased’s family members. The defense also pointed to the High Court’s observation that the alleged dowry demand was improbable given the financial status of the families involved.

Submissions by Parties

Issues Framed by the Supreme Court

1. Whether the High Court was justified in overturning the Trial Court’s conviction of the husband under Section 304B of the I.P.C.
2. Whether the prosecution sufficiently proved the essential ingredients of Section 304B of the I.P.C., particularly the demand for dowry and the proximate link between the demand and the death of the deceased.

Treatment of the Issue by the Court

Authorities

• Surender Kumar Singh Vs. State of U.P. [(2009) 17 SCC 243]: The Court considered the effect of Section 113B of the Evidence Act on Section 304B of the I.P.C., emphasizing that the presumption under Section 113B would not be available if any of the essential ingredients of Section 304B are absent.
• Darshan Singh vs. State of Punjab [(2024) 3 SCC 164]: The Court referred to this case to highlight that if witnesses fail to mention the involvement of an accused in their statements under Section 161 Cr.P.C., their subsequent statements during the trial cannot be relied upon.
• Constable 907 Surender Singh Vs. State of Uttarakhand [2025 INSC 114]: The Court reiterated the principle that appellate courts should be slow in reversing an order of acquittal unless the findings are perverse or based on a misreading of evidence.

Authorities Considered by the Court

Judgment

How each submission made by the Parties was treated by the Court?

How each authority was viewed by the Court?

• Surender Kumar Singh Vs. State of U.P. [(2009) 17 SCC 243]: The Court relied on this case to emphasize the necessity of proving all essential ingredients of Section 304B of the I.P.C. for the presumption under Section 113B of the Evidence Act to apply.
• Darshan Singh vs. State of Punjab [(2024) 3 SCC 164]: The Court used this case to support its view that omissions in the Section 161 Cr.P.C. statements of witnesses are material contradictions that undermine the prosecution’s case.
• Constable 907 Surender Singh Vs. State of Uttarakhand [2025 INSC 114]: The Court cited this case to reinforce the principle that appellate courts should be cautious in reversing acquittals unless there are compelling reasons to do so.

What weighed in the mind of the Court?

The Supreme Court’s decision to acquit the husband was primarily influenced by the lack of concrete evidence supporting the dowry demand. The Court emphasized that the prosecution failed to establish a clear link between the alleged dowry demand and the death of the deceased. Material omissions in the statements of key witnesses, along with the improbability of the dowry demand given the financial status of the families, weighed heavily in the Court’s reasoning.

Sentiment Analysis of Reasons Given by the Supreme Court

Fact:Law Ratio Analysis

The court’s decision was more influenced by the factual aspects of the case, particularly the lack of evidence and inconsistencies in witness statements, than by purely legal considerations.

Logical Reasoning

The court’s logical reasoning can be summarized as follows:

Allegation of Dowry Death -> Examination of Evidence -> Lack of Concrete Evidence of Dowry Demand -> Material Omissions in Witness Statements -> Improbability of Dowry Demand -> Hostile Witness Testimony -> Failure to Prove Essential Ingredients of Section 304B IPC -> Acquittal of the Accused

The Supreme Court rejected alternative interpretations due to the failure of the prosecution to provide sufficient evidence to support the charges. The final decision was based on a thorough evaluation of the evidence presented and the application of relevant legal principles.

The reasons for the decision include:

• Failure to prove the essential ingredient of dowry demand.
• Material omissions in the statements of key witnesses.
• Improbability of the dowry demand given the financial status of the families.
• Hostile testimony from the landlord, contradicting the prosecution’s claim.

“The essential ingredient of a demand of dowry being absent under Section 304B of the I.P.C., we cannot find the suicidal death; though, categorized as an unnatural one, as one akin to murder inviting a punishment under Section 304B of the I.P.C.”

“On a reading of the evidence recorded at trial, we are of the considered opinion that the demand of dowry was not proved by the prosecution.”

“Both PWs 1 and 2 admitted in their deposition that they had not personally witnessed any physical violence on the wife and PW 2-the father also deposed that the son-in-law was quite aware of his financial condition; which would not have enabled him to raise ₹4,00,000/- or purchase a plot for construction of a house.”

Key Takeaways

• The prosecution must provide concrete evidence of dowry demand to secure a conviction under Section 304B of the I.P.C.
• Omissions and contradictions in witness statements can significantly undermine the prosecution’s case.
• The financial status of the families involved can be a relevant factor in assessing the probability of dowry demands.
• Appellate courts will be cautious in reversing acquittals unless there are compelling reasons to do so.

Directions

No specific directions were given by the Supreme Court in this judgment.

Specific Amendments Analysis

This judgment does not discuss any specific amendments.

Development of Law

The ratio decidendi of this case is that the prosecution must provide concrete and consistent evidence of dowry demand to secure a conviction under Section 304B of the I.P.C. The judgment reinforces the importance of scrutinizing witness testimonies for omissions and contradictions and considering the financial status of the families involved.

Conclusion

In Criminal Appeal No. 112/2014, the Supreme Court upheld the High Court’s decision to acquit the husband, emphasizing the lack of concrete evidence supporting the dowry demand. The Court reiterated the need for caution in dowry death cases and highlighted the importance of scrutinizing witness testimonies for omissions and contradictions. The judgment reinforces the principle that the prosecution must prove all essential ingredients of Section 304B of the I.P.C. to secure a conviction.