Supreme Court Partially Upholds Conviction in Dowry Death Case: Kuljit Singh & Anr. vs. State of Punjab (2021)

Date of the Judgment: 08 December 2021

Citation: (2021) INSC 723

Judges: N.V. Ramana, CJI, A.S. Bopanna, J., and Hima Kohli, J. The judgment was authored by Justice A.S. Bopanna.

Can a mother-in-law be convicted of dowry death based on general allegations of cruelty, or does the prosecution need to prove her specific role? The Supreme Court of India addressed this question in a case involving the death of a young woman within two years of her marriage. The court examined whether the evidence presented was sufficient to convict both the husband and the mother-in-law under Section 304B of the Indian Penal Code (IPC), which deals with dowry deaths. This case highlights the importance of specific evidence in dowry death cases, particularly when multiple family members are accused.

Case Background

The case revolves around the death of Manju, who married Kuljit Singh (Appellant No. 1) in 1997. Manju died on March 2, 1999, within two years of her marriage, due to consuming insecticide. The prosecution argued that Manju’s death was a dowry death, caused by the cruelty and harassment she faced from her husband and in-laws for dowry demands. The prosecution alleged that demands for a television set and ₹10,000 were made since the marriage.

The prosecution’s case rested on the testimonies of Manju’s parents, Gurnam Singh (PW1) and Charanjit Kaur (PW8), and another witness, Bidhi Chand (PW7). They stated that Manju was subjected to cruelty and harassment for dowry. The parents also testified that Manju was sent back to her parental home to fulfill the dowry demands, and upon their inability to do so, she was sent back to her marital home. Manju had also mentioned the ill-treatment she faced during her visits to her parents.

Timeline:

Course of Proceedings

The Sessions Court, Amritsar, convicted both Kuljit Singh and his mother, Raj Rani (Appellant No. 2), under Section 304B of the Indian Penal Code. The High Court of Punjab and Haryana dismissed their appeal, upholding the conviction, but modified the sentence of Raj Rani to 7 years. Aggrieved by this, the appellants approached the Supreme Court.

Legal Framework

The case is primarily concerned with Section 304B of the Indian Penal Code, which deals with dowry death. This section states:

“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.”

For a conviction under Section 304B of the Indian Penal Code, the prosecution must prove:

• ✓ The death of a woman occurred within seven years of her marriage.
• ✓ The death was not under normal circumstances.
• ✓ The woman was subjected to cruelty or harassment by her husband or his relatives.
• ✓ The cruelty or harassment was in connection with a demand for dowry.

Arguments

Appellants’ Arguments:

• ✓ The counsel for the appellants argued that the evidence against Raj Rani (Appellant No. 2) was vague and lacked specific instances of her involvement in dowry demands or cruelty.
• ✓ They contended that the trial court and High Court had made general statements about the in-laws’ involvement without specifying Raj Rani’s particular role.
• ✓ Raj Rani, in her statement under Section 313 of the Code of Criminal Procedure, 1973, denied any role and claimed she was not present when Manju died.

Respondent’s Arguments:

• ✓ The prosecution argued that the evidence presented by the parents of the deceased (PW1 and PW8) and another witness (PW7) established that there were persistent demands for dowry (television and ₹10,000) since the marriage.
• ✓ They argued that the evidence showed that the deceased was sent back to her parental home to fulfill the dowry demands, and upon their inability to do so, she was sent back to her marital home, during which she mentioned ill-treatment.
• ✓ The prosecution contended that the death was unnatural, and the circumstances of the death, along with the dowry demands, were sufficient to convict both appellants under Section 304B of the Indian Penal Code.

Issues Framed by the Supreme Court

The primary issue before the Supreme Court was:

1. Whether the conviction and sentence handed down to the appellant No. 2 (Raj Rani) is justified or not?

Treatment of the Issue by the Court

Authorities

The court considered the following:

• ✓ Section 304B of the Indian Penal Code, 1860: The court examined the requirements for a conviction under this section, which deals with dowry death.

Judgment

How each authority was viewed by the Court?

The Court carefully examined Section 304B of the Indian Penal Code, 1860, emphasizing that for a conviction, the prosecution must establish that the accused subjected the woman to cruelty or harassment for dowry demand. The court found that while the requirements of unnatural death within 7 years of marriage were met, the evidence did not prove Raj Rani’s individual involvement in the cruelty or harassment. The court held that the evidence was sufficient to convict Kuljit Singh (Appellant No. 1) because his presence at the scene and his role in the dowry demand was established, but the same was not true for Raj Rani.

What weighed in the mind of the Court?

The Supreme Court’s decision was primarily influenced by the lack of specific evidence against Raj Rani. The court emphasized that general allegations of cruelty and harassment against the in-laws were insufficient to convict her. The court highlighted that the prosecution needed to prove Raj Rani’s direct involvement in making dowry demands or inflicting cruelty on the deceased. The court also noted that Raj Rani’s presence at the time of the incident was not established, further weakening the case against her. The court’s focus was on ensuring that each accused is held responsible only for their individual actions and not on general allegations.

The court’s reasoning was primarily based on the principle that each accused must be held accountable for their individual actions. The court emphasized the need for specific evidence linking Raj Rani to the dowry demands and the cruelty inflicted on the deceased. The court noted that the prosecution relied on general statements about the in-laws’ involvement without specifying Raj Rani’s particular role. The court stated:

“From the evidence referred by the trial court, it is noticed that wherever this aspect has been referred to, a sweeping statement has been made that the husband and in-laws of the deceased had inflicted cruelty or it has been stated that the husband and his mother had done so, without specifying their roles.”

The court further observed:

“Apart from that, there is no specific evidence with regard to such demand being made by the appellant No.2 or cruelty being inflicted by her pursuant to such demand.”

The court concluded:

“Hence, we are of the opinion that the appellant No.2 (Raj Rani) is entitled to be acquitted.”

Key Takeaways

• ✓ In dowry death cases, general allegations against in-laws are not sufficient for conviction. The prosecution must prove the specific role of each accused.
• ✓ The presence of an accused at the scene of the crime, and their specific role in the crime must be established to secure a conviction.
• ✓ This judgment reinforces the principle that each accused is responsible for their individual actions and not for the actions of others.
• ✓ This case serves as a reminder for the prosecution to gather specific and detailed evidence against each accused in dowry death cases.

Directions

The Supreme Court directed that:

• ✓ Kuljit Singh (Appellant No. 1), who was on bail, must surrender within two weeks to serve the remaining sentence.
• ✓ Raj Rani (Appellant No. 2) was set at liberty if not required in any other case, and her bail bonds were cancelled.

Development of Law

The ratio decidendi of this case is that in dowry death cases under Section 304B of the Indian Penal Code, 1860, the prosecution must provide specific evidence of each accused’s direct involvement in dowry demands and cruelty or harassment. General allegations against family members are not sufficient for conviction. This judgment reinforces the need for individual accountability in criminal cases, particularly in dowry death cases.

Conclusion

The Supreme Court partially allowed the appeal, upholding the conviction of Kuljit Singh (Appellant No. 1) while acquitting Raj Rani (Appellant No. 2). The court emphasized that general allegations of cruelty and harassment against in-laws are insufficient for conviction under Section 304B of the Indian Penal Code. The prosecution must provide specific evidence linking each accused to the dowry demands and the cruelty inflicted on the deceased. This judgment underscores the importance of individual accountability and specific evidence in dowry death cases.