Supreme Court Reinstates Charges in Dowry Death Case: Ranjeet Mittal vs. State of Madhya Pradesh (2024) INSC 766

Date of the Judgment: September 3, 2024
Citation: 2024 INSC 766
Judges: Vikram Nath, J., Prasanna B. Varale, J.
Can a High Court quash charges framed by a trial court based on a detailed charge sheet and witness statements? The Supreme Court recently addressed this question in a case concerning the death of a woman in her matrimonial home. The court examined whether the High Court was correct in setting aside the trial court’s order framing charges against the deceased’s husband and in-laws for offences related to dowry harassment, abetment to suicide, and murder. The bench comprised Justices Vikram Nath and Prasanna B. Varale, who delivered the judgment.

Case Background

The case revolves around the death of Anjali Agarwal, who was married to Sulabh Agarwal on May 6, 2006. Anjali lived with her husband and in-laws, Madhu Agarwal and Kailash Babu Agarwal, in Vidisha, Madhya Pradesh. The couple had two children, a daughter born three years into the marriage and a son born in 2015. On March 10, 2018, Anjali was found dead, having allegedly fallen from the terrace of her house. A Merg intimation was registered at the local police station, and a post-mortem examination was conducted, which indicated that the cause of death was hemorrhage and shock.

On the day of the incident, a neighbor, Sandeep Sunhare, found Anjali lying on her stomach near a back door of another house. He informed her husband, Sulabh Agarwal, who then took her to a hospital via handcart. Another neighbor, Mona Singh, noted that Anjali was not wearing any jewelry on her hands or feet at the time. Following an investigation, an FIR was filed on May 17, 2018, against Sulabh Agarwal under Sections 498A (dowry harassment) and 306 (abetment to suicide) of the Indian Penal Code (IPC). Later, Sections 201 (causing disappearance of evidence) and 34 (common intention) of the IPC were added against Sulabh and his parents and sister.

The police filed a charge sheet on September 27, 2019, and the trial court framed charges against the accused. Sulabh was charged under Sections 498A, 306 read with Section 34, and in the alternative, Section 302 (murder) read with Section 34 and Section 201 of the IPC. His parents and sister were charged under Sections 498A, 306 read with Section 34, and in the alternative, Section 302 read with Section 34 of the IPC.

Timeline

Course of Proceedings

The accused, aggrieved by the trial court’s order framing charges, filed Criminal Revisions before the High Court of Judicature at Madhya Pradesh. The High Court allowed the revisions, quashing the charges against all the accused. The High Court reasoned that there was no prima facie evidence to suggest that the accused had abetted Anjali to commit suicide, and the allegations were deemed omnibus. The High Court also noted that the case appeared to be a family dispute, not a case of abetment to suicide or murder. The complainant, Ranjeet Mittal, then appealed to the Supreme Court against the High Court’s order.

Legal Framework

The case involves several sections of the Indian Penal Code, 1860:

• Section 498A: “Husband or relative of husband of a woman subjecting her to cruelty.” This section deals with cruelty towards a married woman by her husband or his relatives.
• Section 306: “Abetment of suicide.” This section addresses the act of instigating or aiding someone to commit suicide.
• Section 302: “Punishment for murder.” This section defines the punishment for the act of murder.
• Section 201: “Causing disappearance of evidence of offence, or giving false information to screen offender.” This section deals with the act of destroying evidence or giving false information to protect an offender.
• Section 34: “Acts done by several persons in furtherance of common intention.” This section states that when a criminal act is done by several persons in furtherance of the common intention of all, each of such persons is liable for that act in the same manner as if it were done by him alone.

Arguments

Appellant’s Arguments:

• The appellant, Anjali’s brother, argued that the phone call between Anjali and Alok Kumar, an hour before the incident, indicated foul play. Anjali was crying and asking for help, and her husband was abusive towards Alok.
• The manner in which Anjali was taken to the hospital, via handcart instead of a car, raised suspicion, suggesting that her husband did not want to save her life.
• The fact that Anjali was not wearing any jewelry at the time of the incident also cast doubt on the conduct of the accused.
• The appellant contended that there was a possibility that the accused had pushed Anjali from the terrace.

Respondent’s Arguments:

• The respondents, Anjali’s husband and in-laws, argued that the FIR was registered due to media pressure.
• They claimed that the handcart was used to take Anjali to the hospital because it was close by, and using a car would have taken longer.
• They submitted that mere harassment does not amount to abetment to suicide and that there was no overt act to instigate Anjali to commit suicide.
• They also argued that the medical reports confirmed that Anjali’s injuries were consistent with a fall from the terrace.

Issues Framed by the Supreme Court

The Supreme Court did not explicitly frame specific issues in the provided text. However, the core issue before the court was whether the High Court was justified in quashing the charges framed by the trial court against the accused.

Treatment of the Issue by the Court

Authorities

The Supreme Court relied on the following authority:

• CBI v. Aryan Singh, 2023 SCC OnLine SC 379, Supreme Court of India: This case was cited to emphasize that at the stage of discharge or quashing of criminal proceedings, the court is not required to conduct a mini-trial. The court’s role is limited to assessing whether sufficient material exists to proceed against the accused.

Judgment

What weighed in the mind of the Court?

The Supreme Court was primarily influenced by the following factors:

• The statements of witnesses indicated that Anjali was subjected to abuse and ill-treatment in her matrimonial home.
• The serious argument between Anjali and her husband shortly before her death was a significant factor.
• The suspicious circumstances surrounding Anjali’s death, including being taken to the hospital via handcart and the absence of jewelry on her body, raised doubts about the conduct of the accused.
• The Court emphasized that at the stage of framing charges, a detailed inquiry into the evidence is not necessary and that there was sufficient prima facie evidence to proceed with the trial.

The Court’s reasoning was based on the principle that at the stage of framing charges, a mini-trial is not required. The Court’s role is to determine if there is sufficient material to proceed against the accused. The Court found that the statements of witnesses, along with the suspicious circumstances surrounding Anjali’s death, constituted sufficient grounds for a trial. The Court stated, “it would be travesty of justice to put a complete stop on criminal proceedings.” The Court also noted, “Given the statements of witnesses, suspicious circumstances around death of deceased and gravity of offense, we are of the opinion that the trial needs to be conducted to reach to the truth.” The Court reiterated, “As per the cardinal principle of law, at the stage of discharge and/or quashing of the criminal proceedings, while exercising the powers under Section 482 Cr. P.C., the Court is not required to conduct the mini trial.”

Key Takeaways

• The Supreme Court emphasized that at the stage of framing charges, a detailed inquiry into the evidence is not necessary.
• If there is sufficient prima facie evidence, including witness statements and suspicious circumstances, a trial should be conducted.
• High Courts should be cautious in quashing charges framed by trial courts, especially in cases involving serious offenses.
• The case highlights the importance of witness testimonies and circumstantial evidence in cases of dowry harassment and death.

Directions

The Supreme Court set aside the order of the High Court and directed the trial court to proceed with the trial from the stage of framing of charges. The Court clarified that any observations made in its order should not influence the trial court, which should decide the case based on the evidence led before it.

Development of Law

The Supreme Court reiterated the principle that at the stage of framing charges, a mini-trial is not required. The Court’s role is limited to assessing whether sufficient material exists to proceed against the accused. This decision reinforces the importance of allowing the trial process to unfold when there is prima facie evidence of an offense. The ratio decidendi of the case is that when there is sufficient prima facie evidence, including witness statements and suspicious circumstances, a trial should be conducted to ascertain the truth.

Conclusion

The Supreme Court allowed the criminal appeals, setting aside the High Court’s order that had quashed the charges against the accused. The Court found that there was sufficient prima facie evidence to proceed with the trial. The case underscores the importance of a thorough trial process in cases involving serious offenses, especially where there are allegations of dowry harassment and suspicious circumstances surrounding the death of a woman.