Supreme Court Upholds Acquittal in Dowry Death Case: State of A.P. vs. Guvva Satyanarayana (24 September 2008)

Introduction

Date of the Judgment: 24 September 2008

Judges: Dr. Arijit Pasayat, J., Dr. Mukundakam Sharma, J.

Did the Andhra Pradesh High Court err in acquitting the accused in a dowry death case? The Supreme Court addressed this question in State of A.P. v. Guvva Satyanarayana. This case revolves around the death of a wife allegedly due to dowry harassment, and whether the dying declaration was reliable enough to convict the husband. The Supreme Court of India, comprising of Justice Dr. Arijit Pasayat and Justice Dr. Mukundakam Sharma, examined the High Court’s decision to acquit the accused, focusing on the veracity of the dying declaration and other evidence presented.

Case Background

The case involves the death of Smt. Guvva Renuka, who was married to the accused, Guvva Satyanarayana, seven years prior to her death. At the time of the marriage, the accused received ₹5,000 and 3 tolas of gold. Initially, their married life was harmonious, but after a year, the accused began demanding ₹5,000 from Renuka’s parents. When she failed to meet this demand, he allegedly subjected her to physical and mental harassment. Despite admonishment in a panchayat, his behavior did not change, and he continued to beat Renuka while intoxicated. On April 11, 1994, at approximately 8:30 p.m., the accused allegedly quarreled with Renuka, doused her with kerosene, and set her on fire.

Renuka’s paternal uncle, Pittala Anjaneyulu (PW-1), reported the incident to the Bhongir town police at 9:15 p.m. Y. Venkat Reddy, Sub-Inspector (PW-11), registered the case and visited the scene of the crime, preparing a panchanama (Ex.P.3) in the presence of witnesses. He seized a 5-liter kerosene empty tin (M.O.I.) and created a rough sketch of the scene. Renuka was initially taken to Government Hospital, Bhongir, and subsequently transferred to Gandhi Hospital, Secunderabad.

While at Gandhi Hospital, Sri K. Seetharam Naidu, XIII Metropolitan Magistrate, Secunderabad (PW-9), recorded Renuka’s dying declaration on the same night, in the presence of Dr. I. Bhaskara Raju (PW-12), Casualty Medical Officer. Renuka succumbed to her injuries on April 23, 1994. Following her death, the Sub-Inspector (PW-11) requested M.R.O. PW-8 to conduct an inquest, which was performed in the presence of PW-7 and another panch. The inquest panchnamma is marked as Ex.P.4. Dr. N. Dudaiah (PW-10) performed the autopsy and issued the post-mortem examination report (Ex.P.8).

The Additional Judicial Magistrate, 1st Class, Bhongir, filed a charge sheet, and the case was committed to the Court of Sessions, Nalgonda. The I Addl. Sessions Judge, Nalgonda, framed charges under Sections 498-A and 302 of the Indian Penal Code. The accused pleaded not guilty, leading to a trial.

Timeline

Course of Proceedings

The trial Court convicted the accused based on the dying declaration, sentencing him under Sections 302 and 498A of the Indian Penal Code. However, in appeal, the High Court set aside the conviction under Section 302, finding the dying declaration to be suspicious. The High Court, however, upheld the conviction under Section 498A IPC, enhancing the sentence from two to three years of rigorous imprisonment.

Legal Framework

The legal framework of this case primarily involves two sections of the Indian Penal Code, 1860:

• Section 302, IPC: Deals with the punishment for murder. It states that “Whoever commits murder shall be punished with death, or imprisonment for life, and shall also be liable to fine.”
• Section 498A, IPC: Addresses cruelty by husband or relatives of husband for dowry. It states that “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.”

Arguments

Arguments by the Appellant (State of A.P.):

• The counsel for the appellant argued that the High Court was not justified in discarding the dying declaration.
• In the dying declaration, the deceased stated that her husband poured kerosene on her and set her on fire with the intention to kill her.
• The deceased explained that her husband committed the act because she could not bring money from her mother, who was a widow and unable to pay the demanded amount.

Arguments by the Respondent (Guvva Satyanarayana):

• The first information report (FIR) stated that the deceased committed suicide by setting herself on fire after pouring kerosene.
• PW-1, the informant, admitted that the report was based on information from a boy, but no inquiry was made from the deceased.
• The deceased was allegedly unconscious and regained consciousness only the next day around noon, which contradicts the fact that her dying declaration was recorded at 5:40 a.m. on April 12, 1994.
• Hospital records (Ex.P/12) indicated that the deceased stated she sustained burns accidentally at her residence and was conscious and coherent upon admission.

Issues Framed by the Supreme Court

1. Whether the High Court was justified in discarding the dying declaration.

Treatment of the Issue by the Court

Authorities

The court considered the evidence presented, including the dying declaration, the first information report, and the hospital records. The primary point of contention was the reliability and consistency of the dying declaration given the other evidence on record.

Judgment

What weighed in the mind of the Court?

The Supreme Court’s decision was primarily influenced by the inconsistencies and doubts surrounding the dying declaration. The court noted that the initial FIR suggested suicide, and the hospital records indicated that the deceased reported accidental burns. These discrepancies, along with the testimony of witnesses, led the court to believe that the dying declaration was not reliable enough to base a conviction on.

Key Takeaways

• The judgment emphasizes the importance of consistency and reliability in dying declarations.
• It highlights the need for thorough investigation and corroboration of evidence in dowry death cases.
• The decision reinforces the principle that a conviction cannot be based solely on a dying declaration if there are significant doubts about its truthfulness.

Development of Law

The ratio decidendi of this case is that a dying declaration must be free from suspicion and consistent with other evidence to be the sole basis for conviction. The judgment reinforces the existing legal position that the courts must carefully scrutinize dying declarations and consider all surrounding circumstances before relying on them.

Conclusion

In conclusion, the Supreme Court dismissed the appeal, upholding the High Court’s decision to acquit the accused. The decision was based on the inconsistencies and doubts surrounding the dying declaration, as well as contradictory evidence and witness statements. This case underscores the importance of reliable and consistent evidence in dowry death cases and reinforces the principle that a conviction cannot be solely based on a suspicious dying declaration.