A) ABSTRACT / HEADNOTE

The judgment concerns the scope and limits of Section 304B of the Indian Penal Code, 1860, dealing with dowry death, and the corresponding presumption under Section 113B of the Indian Evidence Act, 1872. The Supreme Court examined whether the High Court was justified in reversing an order of acquittal passed by the Sessions Court in a case alleging dowry death by poisoning. The deceased, married within seven years of her death, was found dead under circumstances alleged to be unnatural. The prosecution relied primarily on circumstantial evidence, assertions of dowry demand, and alleged poisoning.

The Supreme Court undertook a meticulous reappreciation of evidence, emphasizing that proof of unnatural death and cruelty or harassment soon before death in connection with dowry demand are foundational requirements under Section 304B IPC. The Court found that the prosecution failed to establish poisoning as the cause of death, particularly in light of the Forensic Science Laboratory report negating the presence of poison and medical testimony suggesting alternate natural causes such as tuberculosis.

The Court also scrutinized contradictions in testimonies regarding the alleged demand of ₹10 lakhs and found them irreconcilable. Importantly, the Court reiterated the settled principle that appellate courts should not lightly interfere with acquittals unless findings are perverse or manifestly illegal. Holding that the High Court exceeded its appellate jurisdiction, the Supreme Court restored the acquittal.

Keywords:
Dowry death, Section 304B IPC, Section 113B Evidence Act, poisoning, appellate interference, presumption of innocence

B) CASE DETAILS

C) INTRODUCTION AND BACKGROUND OF JUDGMENT

The judgment arises from an appeal against the reversal of acquittal by the Uttarakhand High Court in a prosecution for dowry death. The appellants included the husband and parents-in-law of the deceased. The trial court had acquitted them, holding that the prosecution failed to prove essential ingredients of Section 304B IPC.

The High Court, however, reversed the acquittal and convicted the appellants, primarily relying on circumstantial evidence and invoking the presumption under Section 113B of the Evidence Act. This reversal prompted the appeal before the Supreme Court.

The background of the case reveals systemic issues frequently encountered in dowry death prosecutions—overreliance on presumptions, weak forensic linkage, and contradictions in testimonial evidence. The Supreme Court approached the matter by reasserting the doctrinal safeguards surrounding criminal jurisprudence, especially the double presumption of innocence following an acquittal.

The judgment is significant for its careful distinction between suspicion and proof, and for reaffirming the evidentiary thresholds necessary to sustain a conviction under Section 304B IPC. It also clarifies the legal parameters governing appellate interference with acquittals.

D) FACTS OF THE CASE

The deceased was married to the first appellant on 10 December 2009. Her death occurred on 23 January 2011, within seven years of marriage. An FIR was lodged by her father alleging that the appellants harassed his daughter for dowry and caused her death by poisoning.

According to the prosecution, a demand of ₹10 lakhs was made by the husband for construction of a house. It was alleged that failure to meet this demand resulted in cruelty and eventual poisoning of the deceased. The dead body was found in a Santro car parked near the matrimonial home.

The prosecution examined 11 witnesses, including family members of the deceased and the post-mortem doctor. The defence examined four medical witnesses, who testified regarding the deceased’s prior medical history, including tuberculosis, eosinophilia, anaemia, and low body weight.

The post-mortem report did not determine a definitive cause of death. No external injuries were found. The viscera report conclusively ruled out the presence of poison. No poisonous substance was recovered from the appellants’ house.

The trial court found serious contradictions regarding the alleged dowry demand and held that the prosecution failed to establish unnatural death. Accordingly, the appellants were acquitted. The High Court reversed this finding, leading to the present appeal.

E) LEGAL ISSUES RAISED

i. Whether the prosecution proved that the death of the deceased was unnatural as required under Section 304B IPC?
ii. Whether the alleged demand of ₹10 lakhs constituted a dowry demand in law?
iii. Whether the presumption under Section 113B of the Evidence Act was rightly invoked?
iv. Whether the High Court was justified in reversing the acquittal without finding perversity in the trial court’s judgment?

F) PETITIONER / APPELLANT’S ARGUMENTS

The counsels for the appellants submitted that the prosecution failed to establish the foundational facts required under Section 304B IPC. It was argued that there was no proof of poisoning, as confirmed by the FSL report and medical evidence.

They emphasized contradictions in witness testimonies regarding the timing, purpose, and payment of the alleged ₹10 lakhs. It was argued that even if money was sought, it was for a loan, not dowry.

The appellants contended that the deceased had a documented history of tuberculosis and related ailments, which could naturally explain the death. The High Court, it was argued, exceeded its appellate jurisdiction by substituting its own view without finding the trial court’s judgment perverse.

G) RESPONDENT’S ARGUMENTS

The counsels for the respondent-State submitted that the death occurred within seven years of marriage and was therefore suspicious. They argued that cruelty and harassment for dowry were proved through family witnesses.

It was contended that absence of poison in viscera was not decisive and that circumstantial evidence established poisoning. Reliance was placed on the fact that the deceased was found dead in a car near the matrimonial home, and the accused failed to explain the circumstances under Section 313 CrPC.

H) JUDGMENT

The Supreme Court allowed the appeal and set aside the High Court judgment. It held that the essential ingredient of unnatural death was not proved. The Court relied heavily on medical and forensic evidence, which ruled out poisoning and suggested alternative natural causes.

The Court found the testimonies regarding dowry demand riddled with contradictions and held that the alleged ₹10 lakhs demand could not be conclusively categorized as dowry. The presumption under Section 113B was held inapplicable due to failure to prove cruelty “soon before death.”

The Court reiterated that appellate courts must exercise restraint while overturning acquittals and restored the trial court’s judgment.

a) RATIO DECIDENDI

A conviction under Section 304B IPC cannot be sustained unless the prosecution proves unnatural death and dowry-related cruelty soon before death. Presumption under Section 113B Evidence Act arises only after foundational facts are established. Appellate interference with acquittal requires compelling reasons and proof of perversity.

b) OBITER DICTA

The Court observed that courts must guard against mechanical application of dowry death presumptions and emphasized the importance of forensic science in criminal adjudication.

c) GUIDELINES

i. Proof of unnatural death is mandatory under Section 304B IPC.
ii. Contradictory evidence regarding dowry demand weakens prosecution case.
iii. Presumption under Section 113B is not automatic.
iv. Acquittals should not be reversed unless findings are perverse or illegal.

I) CONCLUSION & COMMENTS

The judgment reinforces evidentiary discipline in dowry death cases and protects against conviction based on conjecture. It reaffirms constitutional values of personal liberty and presumption of innocence, ensuring that criminal liability is imposed only upon strict proof.

J) REFERENCES

a) Important Cases Referred

• Anant Chintaman Lagu v. State of Bombay, AIR 1960 SC 500

• Bhupinder Singh v. State of Punjab, [1988] 3 SCR 409

• Ghurey Lal v. State of Uttar Pradesh, [2008] 11 SCR 499

• Chhotan Sao v. State of Bihar, [2013] 17 SCR 843

b) Important Statutes Referred

• Indian Penal Code, 1860

• Indian Evidence Act, 1872

• Code of Criminal Procedure, 1973