Supreme Court Upholds Conviction for Abetment of Suicide in Dowry Harassment Case: Shakuntla Devi vs. State of Uttar Pradesh (2025)

Introduction

Date of the Judgment: April 25, 2025
Citation: 2025 INSC 581
Judges: Vikram Nath, J., Sanjay Karol, J., Sandeep Mehta, J.

When does the relentless torment for dowry cross the line into abetment of suicide? The Supreme Court of India recently examined this question in Shakuntla Devi vs. State of Uttar Pradesh, a case involving a mother-in-law accused of driving her daughter-in-law to suicide through persistent harassment related to dowry demands. The court addressed whether the High Court was correct in altering the conviction from dowry death to abetment of suicide. The judgment was delivered by a bench comprising Justices Vikram Nath, Sanjay Karol, and Sandeep Mehta.

Case Background

Smt. Kusum, a 22-year-old woman, was married to Rajendra Kumar, the son of the accused Shakuntla Devi, on May 14, 1997. Tragically, Smt. Kusum died at her matrimonial home on May 4, 1998. Following her death, on May 8, 1998, the deceased’s father filed a First Information Report (FIR) against Shakuntla Devi, alleging offences under Sections 498A (cruelty towards a married woman) and 304B (dowry death) of the Indian Penal Code, 1860, as well as Sections 3 and 4 of the Dowry Prohibition Act, 1961.

The FIR detailed that Smt. Kusum had repeatedly informed her family that her mother-in-law, Shakuntla Devi, subjected her to mental and physical torture due to insufficient dowry. On April 25, 1998, Smt. Kusum returned to her parental home and disclosed that Shakuntla Devi had demanded an additional Rs. 25,000 and a gold chain. Due to a wedding in another village, Smt. Kusum’s parents, concerned about leaving her alone in her pregnant condition, convinced her to return to her marital home on May 1, 1998, accompanied by her younger brother, Sandeep Kumar, with the promise to resolve the dowry issue upon their return.

However, upon their return on May 5, 1998, they were informed that Smt. Kusum had died the previous day, May 4, 1998.

Timeline

Course of Proceedings

Following the investigation, a chargesheet was filed, and the Session Judge framed charges against Shakuntla Devi under Sections 498A and 304B of the IPC, along with Sections 3 and 4 of the DP Act. Shakuntla Devi denied the charges and claimed to be tried.

During the trial, the father, mother, and brother of the deceased testified as PW-1, PW-2, and PW-3, respectively. On April 22, 2003, the Trial Court found Shakuntla Devi guilty under Sections 498A and 304B of the IPC, as well as Sections 3 and 4 of the DP Act. She was sentenced to seven years of rigorous imprisonment under Section 304B of the IPC, one year of rigorous imprisonment under Section 498A of the IPC, and one year of rigorous imprisonment under Sections 3 and 4 of the DP Act. The sentences were ordered to run concurrently.

Shakuntla Devi then appealed to the High Court, challenging her conviction and sentence. The High Court, in its order dated March 22, 2018, acquitted her of the charges under Sections 498A and 304B of the IPC and Sections 3 and 4 of the DP Act, stating that these offences were not made out. However, based on the statement of PW-3, Sandeep Kumar, the High Court found that Shakuntla Devi’s behavior had led Smt. Kusum to commit suicide by consuming poison. Consequently, Shakuntla Devi was convicted under Section 306 of the IPC (abetment of suicide) and, considering her age of approximately 70 years, was sentenced to three years of rigorous imprisonment.

Legal Framework

The legal framework relevant to this case includes:

1. Section 304B of the Indian Penal Code, 1860 (Dowry Death): This section deals with dowry death, which occurs when a woman dies within seven years of her marriage due to burns or bodily injury, 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.
2. Section 498A of the Indian Penal Code, 1860 (Cruelty towards a married woman): This section addresses cruelty towards a woman by her husband or any relative of her husband. Cruelty is defined as any willful conduct that is likely to drive the woman to commit suicide or cause grave injury or danger to life, limb, or health, or 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.
3. Section 306 of the Indian Penal Code, 1860 (Abetment of Suicide): This section penalizes the abetment of suicide. If any person commits suicide, whoever abets the commission of such suicide, shall be punished with imprisonment of either description for a term which may extend to ten years, and shall also be liable to fine.
4. Sections 3 and 4 of the Dowry Prohibition Act, 1961: These sections prohibit the giving or taking of dowry and prescribe penalties for demanding dowry.

Arguments

The primary arguments presented by both sides are detailed below:

Appellant’s Arguments:

• The appellant challenged the High Court’s conviction under Section 306 of the IPC, arguing that the evidence did not establish abetment of suicide.
• It was contended that the High Court erred in relying solely on the testimony of PW-3, Sandeep Kumar, to establish that the appellant’s actions drove the deceased to suicide.
• The appellant argued that there was no active act or omission on her part that was intended to push the deceased into committing suicide.

Respondent’s Arguments:

• The State argued that the High Court correctly convicted the appellant under Section 306 of the IPC, based on the evidence presented.
• It was submitted that the repeated torture and abuse of the deceased by the appellant, due to dowry demands, created circumstances that led the deceased to commit suicide.
• The prosecution emphasized the consistency and honesty in the statements of the deceased’s family members, particularly PW-3, who recounted the events leading up to the suicide.

Table of Sub-Submissions:

Issues Framed by the Supreme Court

The Supreme Court addressed the following key issue:

1. Whether the High Court was justified in convicting the appellant under Section 306 of the IPC (abetment of suicide), considering the evidence on record.

Treatment of the Issue by the Court

The following table demonstrates as to how the Court decided the issues:

Authorities

The court considered the following authorities and legal provisions:

• Section 306 of the Indian Penal Code, 1860: Pertaining to abetment of suicide, requiring an active act or omission intended to push the deceased into committing suicide.
• Statements of PW-1, PW-2, and PW-3: Testimonies of the deceased’s family members, particularly the account of events leading up to the suicide by PW-3, Sandeep Kumar.

Table of 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?

• Section 306 of the Indian Penal Code, 1860: The Court relied on this provision to determine whether the appellant’s actions constituted abetment of suicide. The Court emphasized that the offence requires an active act or omission which led the deceased to commit suicide, and this act or omission must have been intended to push the deceased into committing suicide.

What weighed in the mind of the Court?

The Supreme Court’s decision was primarily influenced by the consistent testimonies of the deceased’s family members, particularly the detailed account provided by PW-3, Sandeep Kumar. The Court noted the honesty and fairness in PW-3’s statement, which lent credibility to the prosecution’s case. Additionally, the Court considered the repeated instances of dowry-related harassment and abuse inflicted upon the deceased by the appellant, which created circumstances that ultimately led to the suicide.

Table Ranking of Sentiment Analysis of Reasons Given by the Supreme Court:

Fact:Law Ratio:

The court’s reasoning can be summarized as follows:

Logical Reasoning:

Key Takeaways

Practical Implications:

• This judgment reinforces the importance of holding individuals accountable for actions that drive victims to suicide, particularly in cases of dowry-related harassment.
• It highlights the significance of consistent and credible witness testimonies in establishing the offense of abetment of suicide.

Potential Future Impact:

• The judgment may serve as a precedent for future cases involving abetment of suicide, particularly in the context of dowry harassment.
• It may encourage stricter enforcement of laws aimed at preventing dowry-related abuse and holding perpetrators accountable.

Directions

The Supreme Court directed the appellant to surrender before the Trial Court concerned within four weeks from the date of the judgment. In case the appellant fails to surrender within the stipulated time, the Trial Court was directed to take coercive measures to ensure the appellant serves the remaining period of sentence, as awarded by the High Court.

Development of Law

The ratio decidendi of the case is that repeated acts of harassment and abuse, particularly in the context of dowry demands, can constitute abetment of suicide under Section 306 of the IPC. This judgment reinforces the legal principle that individuals can be held liable for creating circumstances that drive victims to take their own lives.

Conclusion

In Shakuntla Devi vs. State of Uttar Pradesh, the Supreme Court upheld the High Court’s conviction of the appellant under Section 306 of the IPC for abetment of suicide. The Court found that the repeated acts of harassment and abuse inflicted upon the deceased by the appellant, due to dowry demands, created circumstances that led the deceased to commit suicide. The judgment reinforces the importance of holding individuals accountable for actions that drive victims to suicide, particularly in cases of dowry-related harassment.