Supreme Court acquits husband in dowry death case: Karan Singh vs. State of Haryana (2025) INSC 133

Date of the Judgment: January 31, 2025

Citation: 2025 INSC 133

Judges: Abhay S. Oka, J., Ujjal Bhuyan, J.

Can a husband be convicted for dowry death when the prosecution witnesses’ statements about dowry demands are inconsistent and lack specific details of cruelty? The Supreme Court of India recently addressed this critical question, overturning the conviction of a husband accused of dowry death due to inconsistencies and lack of evidence of cruelty. The bench, comprising Justices Abhay S. Oka and Ujjal Bhuyan, delivered the judgment, with Justice Abhay S. Oka authoring the opinion.

Case Background

The appellant, Karan Singh, was married to Asha Rani on June 25, 1996. On April 2, 1998, Asha Rani committed suicide by hanging. The prosecution alleged that Karan Singh and his parents had subjected Asha Rani to cruelty and harassment for dowry, leading to her death. The Sessions Court convicted Karan Singh under Section 304-B (dowry death) and Section 498-A (cruelty by husband or his relatives) of the Indian Penal Code (IPC), while acquitting his parents. The High Court upheld this conviction.

The prosecution relied on the testimonies of Asha Rani’s mother (PW-6), brother (PW-7), and maternal uncle (PW-8). The primary allegations were that Asha Rani was taunted for insufficient dowry, and demands were made for a motorcycle, refrigerator, mixi, furniture, and cash. The prosecution also alleged that Karan Singh had demanded Rs. 60,000 for purchasing a jeep.

Timeline

Course of Proceedings

The Sessions Court convicted Karan Singh for offences under Sections 304-B and 498-A of the IPC, sentencing him to seven years and one year of rigorous imprisonment, respectively. The High Court confirmed this conviction and sentence. Karan Singh then appealed to the Supreme Court of India.

Legal Framework

The Supreme Court examined the provisions of Section 304-B of the Indian Penal Code (IPC), which defines dowry death, and Section 498-A of the IPC, which deals with cruelty by a husband or his relatives. Section 304-B states:

“304-B. Dowry death.—(1) Where the death of a woman is caused by any burns or bodily injury or occurs otherwise than under normal circumstances within seven years of her marriage and it is shown that soon before her death she was subjected to cruelty or harassment by her husband or any relative of her husband for, or in connection with, any demand for dowry, such death shall be called “dowry death”, and such husband or relative shall be deemed to have caused her death.”

The explanation to Section 304-B defines “dowry” as having the same meaning as in Section 2 of the Dowry Prohibition Act, 1961. Section 2 of the Dowry Prohibition Act, 1961, defines dowry as any property or valuable security given or agreed to be given in connection with the marriage.

Section 498-A of the IPC defines cruelty as:

“498-A. Husband or relative of husband of a woman subjecting her to cruelty.—Whoever, being the husband or the relative of the husband of a woman, subjects such woman to cruelty shall be punished with imprisonment for a term which may extend to three years and shall also be liable to fine. Explanation.—For the purposes of this section, “cruelty” means — (a) any wilful conduct which is of such a nature as is likely to drive the woman to commit suicide or to cause grave injury or danger to life, limb or health (whether mental or physical) of the woman; or (b) harassment of the woman where such harassment is with a view to coercing her or any person related to her to meet any unlawful demand for any property or valuable security or is on account of failure by her or any person related to her to meet such demand.”

The court also considered Section 113-B of the Indian Evidence Act, 1872, which creates a presumption of dowry death if it is shown that soon before her death, the woman was subjected to cruelty or harassment for dowry. Section 113-B states:

“113-B. Presumption as to dowry death.-When the question is whether a person has committed the dowry death of a woman and it is shown that soon before her death such woman had been subjected by such person to cruelty or harassment for, or in connection with, any demand for dowry, the Court shall presume that such person had caused the dowry death.”

Arguments

Appellant’s Submissions:

• The appellant’s counsel argued that the prosecution witnesses’ statements regarding dowry demands were inconsistent and contained significant omissions.
• He contended that there was no legal evidence to prove that the appellant demanded dowry or subjected the deceased to cruelty soon before her death.
• The counsel relied on the Supreme Court’s decision in Charan Singh alias Charanjit Singh v. State of Uttarakhand, arguing that the prosecution failed to establish that the deceased was subjected to cruelty or harassment for dowry soon before her death.

State’s Submissions:

• The State’s counsel argued that there was sufficient evidence, particularly from PW-6 and PW-7, to establish the demand for dowry.
• The counsel pointed out that the deceased had informed PW-6 and PW-7 about the demand for Rs. 60,000 for a jeep, and that the appellant himself made this demand.
• The State argued that the presumption under Section 113-B of the Indian Evidence Act should apply, leading to the conclusion that the appellant caused the dowry death.

Issues Framed by the Supreme Court

The Supreme Court addressed the following issue:

1. Whether the prosecution had proved beyond reasonable doubt that the appellant had subjected his wife to cruelty or harassment for, or in connection with, any demand for dowry, soon before her death, thereby attracting the provisions of Section 304-B of the IPC and Section 113-B of the Indian Evidence Act.

Treatment of the Issue by the Court

Authorities

The Court considered the following legal provisions:

• Section 304-B of the Indian Penal Code (IPC) – Dowry Death
• Section 498-A of the Indian Penal Code (IPC) – Cruelty by Husband or Relatives
• Section 113-B of the Indian Evidence Act, 1872 – Presumption as to Dowry Death
• Section 2 of the Dowry Prohibition Act, 1961 – Definition of Dowry

The Court also considered the following case:

• Charan Singh alias Charanjit Singh v. State of Uttarakhand [2023 SCC OnLine SC 454] – Supreme Court of India. This case was relied upon by the appellant to argue that there was no evidence to show that the deceased was subjected to cruelty or harassment soon before her death.

Judgment

How each authority was viewed by the Court?

• The Court analyzed Section 304-B of the IPC* and emphasized that to establish dowry death, it must be proven that the woman was subjected to cruelty or harassment for dowry soon before her death.
• The Court referred to Section 498-A of the IPC* to define cruelty, highlighting that the prosecution must prove specific acts of cruelty.
• The Court explained that the presumption under Section 113-B of the Indian Evidence Act* could not be invoked as the prosecution failed to prove the essential ingredient of cruelty or harassment for dowry soon before death.
• The Court referred to Section 2 of the Dowry Prohibition Act, 1961* to define dowry.
• The Court relied on the ratio of Charan Singh alias Charanjit Singh v. State of Uttarakhand [2023 SCC OnLine SC 454]* to emphasize that the prosecution must prove that the deceased was subjected to cruelty or harassment for dowry soon before her death.

What weighed in the mind of the Court?

The Supreme Court’s decision was primarily influenced by the lack of credible evidence regarding dowry demands and cruelty. The Court noted that the prosecution witnesses’ statements were inconsistent, with significant omissions in their initial statements to the police. The Court emphasized that the essential ingredients of Section 304-B of the IPC—specifically, that the woman was subjected to cruelty or harassment for dowry soon before her death—were not proven. The Court also highlighted that the presumption under Section 113-B of the Indian Evidence Act could not be invoked in the absence of such proof. The Court was also concerned about the Trial Courts repeatedly committing the same mistakes while deciding cases under Section 304-B of the IPC.

Logical Reasoning:

The Court considered alternative interpretations of the evidence but rejected them due to the lack of consistent and reliable testimony. The Court emphasized that the prosecution must prove its case beyond a reasonable doubt, which it failed to do in this instance. The Court’s reasoning was based on the principle that the benefit of the doubt must go to the accused.

The Court’s decision was based on the following reasons:

• The statements of PW-6 and PW-7 regarding dowry demands were inconsistent and contained significant omissions when compared to their initial statements to the police.
• The prosecution failed to prove that the deceased was subjected to cruelty or harassment for dowry soon before her death, which is an essential ingredient of Section 304-B of the IPC.
• The presumption under Section 113-B of the Indian Evidence Act could not be invoked because the prosecution did not establish the necessary preconditions.
• The prosecution did not prove the material ingredients of the offence punishable under Section 304-B.
• Not a single incident of cruelty covered by Section 498-A was proved by the prosecution.

The Court quoted the following from the judgment:

“Therefore, the version of PW -6 in her statements recorded on 2nd April 1998 and 6th April 1998 regarding providing dowry and regarding demands of dowry are omissions.”

“While deposing about the demand of dowry, she has not deposed to any particular act of cruelty or harassment by the appellant. This is an essential ingredient of Section 304 -B. It is not made out from the evidence of PW -6.”

“Therefore, both the offences alleged against the appellant were not proved by the prosecution beyond a reasonable doubt.”

There was no minority opinion.

The Supreme Court’s decision highlights the importance of consistent and credible evidence in dowry death cases. The Court emphasized that mere allegations of dowry demand are insufficient to establish guilt; the prosecution must prove specific acts of cruelty or harassment for dowry soon before death.

The judgment reinforces the principle that the presumption under Section 113-B of the Indian Evidence Act can only be invoked if the prosecution first establishes that the deceased was subjected to cruelty or harassment for dowry soon before her death. This decision may lead to a more cautious approach by trial courts in dowry death cases, ensuring that convictions are based on solid evidence and not merely on suspicion or conjecture.

Key Takeaways

• In dowry death cases, the prosecution must prove beyond a reasonable doubt that the deceased was subjected to cruelty or harassment for dowry soon before her death.
• Inconsistent statements by prosecution witnesses can undermine the case. Significant omissions in initial statements are considered contradictions.
• The presumption under Section 113-B of the Indian Evidence Act cannot be invoked unless the prosecution proves that the deceased was subjected to cruelty or harassment for dowry soon before her death.
• Trial courts must carefully scrutinize the evidence in dowry death cases to ensure that convictions are based on solid proof and not on speculation.
• This judgment reinforces the need for thorough investigation and credible evidence in dowry death cases.

Directions

The Supreme Court directed the State Judicial Academies to step in and provide training to trial court judges on the proper application of Section 304-B of the IPC, emphasizing the need for careful scrutiny of evidence in dowry death cases.

Development of Law

The ratio decidendi of this case is that the prosecution must prove beyond a reasonable doubt that the deceased was subjected to cruelty or harassment for dowry soon before her death to secure a conviction under Section 304-B of the IPC. This decision reinforces the existing legal position and emphasizes the importance of consistent and credible evidence in dowry death cases. There is no change in the previous position of law, but the judgment serves as a reminder of the strict evidentiary standards required in such cases.

Conclusion

The Supreme Court’s decision in Karan Singh vs. State of Haryana highlights the importance of credible evidence in dowry death cases. The Court acquitted the appellant, emphasizing that the prosecution failed to prove that the deceased was subjected to cruelty or harassment for dowry soon before her death. This judgment underscores the need for trial courts to carefully scrutinize evidence and ensure that convictions are based on solid proof, not on speculation or inconsistent statements. The Court also directed State Judicial Academies to train trial court judges on the proper application of Section 304-B of the IPC.

Category

Parent Category: Criminal Law

Child Categories: Dowry Death, Section 304-B, Indian Penal Code, 1860, Section 498-A, Indian Penal Code, 1860, Section 113-B, Indian Evidence Act, 1872, Cruelty, Harassment, Presumption, Evidence, Acquittal, Supreme Court of India

Parent Category: Indian Penal Code, 1860

Child Categories: Section 304-B, Indian Penal Code, 1860, Section 498-A, Indian Penal Code, 1860

Parent Category: Indian Evidence Act, 1872

Child Categories: Section 113-B, Indian Evidence Act, 1872

FAQ

Q: What is dowry death?

A: Dowry death is the death of a woman caused by burns or bodily injury or occurring under unnatural circumstances within seven years of her marriage, where it is shown that she was subjected to cruelty or harassment for dowry soon before her death.

Q: What is the significance of Section 113-B of the Indian Evidence Act?

A: Section 113-B creates a presumption that if a woman dies within seven years of marriage due to unnatural causes and there is evidence of cruelty or harassment for dowry soon before her death, the court will presume that the husband or his relatives caused the dowry death. However, this presumption is applicable only if the prosecution proves the essential ingredient of cruelty or harassment for dowry soon before death.

Q: What constitutes cruelty under Section 498-A of the IPC?

A: Cruelty under Section 498-A includes any wilful conduct likely to drive a woman to suicide or cause grave injury, as well as harassment to coerce her or her relatives to meet unlawful demands for property or valuable security.

Q: What did the Supreme Court decide in this case?

A: The Supreme Court acquitted the husband, Karan Singh, because the prosecution failed to prove that he had subjected his wife to cruelty or harassment for dowry soon before her death. The Court found significant inconsistencies and omissions in the prosecution witnesses’ statements.

Q: What is the practical implication of this judgment?

A: This judgment emphasizes the need for consistent and credible evidence in dowry death cases. It underscores that mere allegations of dowry demand are insufficient for a conviction. The prosecution must prove specific acts of cruelty or harassment for dowry soon before death.