A) ABSTRACT / HEADNOTE

This case revolves around charges under Sections 498A, 304B, and 306 read with Section 34 of the Indian Penal Code (IPC). The appellants included the husband, sister-in-law, and mother-in-law of the deceased, who died by suicide within her matrimonial house under distressing circumstances. The Trial Court and the High Court upheld convictions against the appellants for dowry-related offenses and abetment of suicide. However, the Supreme Court revisited the evidence and concluded that while the case of dowry death under Section 304B IPC was not substantiated, charges under Sections 306 (abetment of suicide) and 498A (cruelty) were established against the husband. The sister-in-law was acquitted due to lack of evidence.

Keywords: Section 498A IPC, Section 304B IPC, Section 306 IPC, Evidence Act Section 113B, Dowry Death, Marital Cruelty.

B) CASE DETAILS

i) Judgement Cause Title: Chabi Karmakar & Ors. v. The State of West Bengal
ii) Case Number: Criminal Appeal No. 1556 of 2013
iii) Judgement Date: 29 August 2024
iv) Court: Supreme Court of India
v) Quorum: Justice Sudhanshu Dhulia and Justice J.B. Pardiwala
vi) Author: Justice Sudhanshu Dhulia
vii) Citation: [2024] 8 S.C.R. 796, 2024 INSC 665
viii) Legal Provisions Involved: Sections 498A, 304B, and 306 IPC; Section 113B of the Evidence Act
ix) Judgments Overruled by the Case: None
x) Related Law Subjects: Criminal Law, Family Law, Evidence Law

C) INTRODUCTION AND BACKGROUND OF JUDGEMENT

The case pertains to a tragic incident where the deceased, within seven years of marriage, took her own life. Her death was allegedly linked to harassment and cruelty by her husband and in-laws, centered on demands for dowry. The prosecution invoked Sections 498A, 304B, and 306 IPC and the presumption under Section 113B of the Evidence Act. The appellants were convicted in the Trial Court, with the High Court upholding the convictions. The Supreme Court’s intervention addressed errors in applying the legal presumption under Section 113B.

D) FACTS OF THE CASE

1. The deceased married appellant no. 2 in March 2003, and the couple had one son.
2. On 2 May 2006, the deceased was found dead by hanging in her matrimonial home.
3. Her family alleged harassment related to dowry demands.
4. The Trial Court convicted the husband and in-laws under Sections 498A, 304B, and 306 IPC, sentencing them to imprisonment.
5. The High Court upheld these convictions.
6. During the pendency of the Supreme Court appeal, the mother-in-law passed away, abating her case.

E) LEGAL ISSUES RAISED

1. Whether the appellants were guilty under Section 304B IPC for dowry death.
2. Whether the evidence established cruelty under Section 498A IPC.
3. Whether the circumstances supported abetment of suicide under Section 306 IPC.
4. Whether the presumption under Section 113B of the Evidence Act was validly applied.

F) PETITIONER/APPELLANT’S ARGUMENTS

1. The appellants argued the absence of credible evidence connecting harassment with dowry demands.
2. They contended that general allegations of cruelty unrelated to dowry did not meet the legal threshold for Section 304B IPC.
3. Counsel highlighted that the deceased’s statements to witnesses lacked corroboration about dowry-related harassment.
4. Appellant no. 1, the sister-in-law, contended her non-involvement as she resided separately from the deceased.

G) RESPONDENT’S ARGUMENTS

1. The State argued the deceased faced persistent harassment, culminating in her suicide.
2. Witnesses testified to cruelty by the husband and in-laws, suggesting dowry demands.
3. The prosecution emphasized the unnatural death within seven years of marriage, invoking Section 113B of the Evidence Act.
4. The State referred to precedents where circumstantial evidence sufficed for Sections 304B and 498A IPC convictions.

H) JUDGEMENT

a. Ratio Decidendi:

1. Dowry Death (Section 304B IPC): The Court held the prosecution failed to establish cruelty “soon before death” connected to dowry demands. Mere general allegations of dowry harassment were insufficient.
2. Cruelty (Section 498A IPC): The evidence established harassment and cruelty by the husband, unrelated to dowry.
3. Abetment of Suicide (Section 306 IPC): The husband’s conduct, including alleged extramarital relations, contributed to the deceased’s decision to take her life.

b. Obiter Dicta:

1. The Court clarified the interpretation of “soon before death” under Section 304B IPC.
2. It emphasized the necessity of specific evidence linking cruelty to dowry demands.

c. Guidelines:

1. Evidence under Section 304B IPC must directly establish cruelty related to dowry “soon before” the death.
2. The presumption under Section 113B of the Evidence Act requires fulfillment of statutory conditions.
3. Courts must meticulously evaluate evidence in cases involving dowry death allegations.

I) CONCLUSION & COMMENTS

This judgment underscores the distinction between cruelty and dowry-related harassment. It safeguards accused individuals from unsubstantiated dowry death allegations while affirming accountability for proven cruelty and abetment. It also stresses the need for precise and corroborative evidence in matrimonial crimes.

J) REFERENCES

a. Important Cases Referred:

1. Charan Singh v. State of Uttarakhand, [2023 SCC OnLine SC 454].
2. Rajinder Singh v. State of Punjab, (2015) 6 SCC 477.
3. State of Madhya Pradesh v. Jogendra & Anr., (2022) 5 SCC 401.

b. Important Statutes Referred:

1. Indian Penal Code (Sections 498A, 304B, 306).
2. Evidence Act (Section 113B).