A) ABSTRACT / HEADNOTE

The judgment examines the legal sustainability of a conviction under Section 304B of the Indian Penal Code, 1860 concerning an alleged dowry death by poisoning. The appellants, being the husband and parents-in-law of the deceased, were acquitted by the Trial Court, but the High Court reversed the acquittal and imposed life imprisonment. The Supreme Court scrutinised whether the essential statutory ingredients of dowry death were satisfied and whether the High Court was justified in overturning a reasoned acquittal.

The Court undertook a meticulous reappreciation of evidence relating to dowry demand, cruelty soon before death, and unnatural death. The prosecution case rested heavily on oral testimonies alleging a demand of Rs. 10 lakhs and a theory of poisoning. However, material contradictions among prosecution witnesses, absence of contemporaneous complaints, lack of medical or forensic proof of poisoning, and credible defence evidence regarding the deceased’s prolonged medical condition were found decisive.

The judgment reiterates that Section 113B of the Evidence Act, 1872 creates a presumption only after the prosecution discharges its foundational burden. The Court clarified that suspicion, however grave, cannot replace proof, and appellate interference with acquittal is permissible only where findings are perverse or manifestly illegal.

By restoring the Trial Court’s acquittal, the Court reaffirmed principles governing dowry death prosecutions, evidentiary standards in poisoning cases, and the limited scope of appellate reversal of acquittals.

Keywords:
Dowry death; Section 304B IPC; poisoning; presumption under Section 113B Evidence Act; appellate interference with acquittal.

B) CASE DETAILS

C) INTRODUCTION AND BACKGROUND OF JUDGEMENT

The case arose from the death of a young married woman within seven years of marriage, triggering prosecution under Section 304B IPC. The legislative intent behind this provision is to curb the social menace of dowry deaths by reversing the evidentiary burden through statutory presumptions. However, such presumption operates only upon proof of specific foundational facts.

The Trial Court, after extensive evaluation of oral, documentary, medical, and forensic evidence, found that the prosecution failed to establish the core elements of dowry death. The High Court reversed this acquittal, primarily relying on circumstantial inferences, alleged dowry demand, and recovery of the body from a car.

The Supreme Court was thus called upon to assess whether the High Court exceeded its appellate jurisdiction by substituting its own view in a case where two plausible views existed, and whether the evidence justified invocation of the statutory presumption under Section 113B of the Evidence Act.

D) FACTS OF THE CASE

The deceased was married to the first appellant on 10 December 2009. She died on 23 January 2011. An FIR was lodged by her father alleging harassment for dowry and death by poisoning. It was alleged that the husband demanded Rs. 10 lakhs for construction purposes and that the deceased was threatened with death if the demand was not met.

The prosecution examined eleven witnesses, including family members and investigating officers. The defence examined four medical witnesses who deposed regarding the deceased’s long-standing medical issues, including tuberculosis, eosinophilia, and severe underweight condition.

Post-mortem examination revealed no external injuries. Viscera analysis and forensic laboratory reports categorically ruled out poisoning. No poisonous substance was recovered from the appellants or their residence. Medical experts opined that death could have resulted from natural causes, including complications arising from tuberculosis.

E) LEGAL ISSUES RAISED

i. Whether the prosecution proved that the death of the deceased was unnatural?
ii. Whether the alleged demand of Rs. 10 lakhs constituted dowry demand under law?
iii. Whether cruelty or harassment was proved soon before death?
iv. Whether the presumption under Section 113B of the Evidence Act was rightly invoked?
v. Whether the High Court was justified in reversing a well-reasoned acquittal?

F) PETITIONER / APPELLANT’S ARGUMENTS

The counsels for the appellants submitted that the High Court ignored settled principles governing appeals against acquittal. It was argued that unnatural death was not proved, which is a sine qua non for Section 304B IPC. The forensic report conclusively ruled out poisoning, and no corroborative medical evidence existed.

It was further contended that alleged dowry demand was inconsistent, contradictory, and not supported by contemporaneous conduct or complaints. Medical evidence showing prolonged illness and severe underweight condition was overlooked by the High Court.

G) RESPONDENT’S ARGUMENTS

The counsels for the respondents submitted that the deceased died within seven years of marriage and that evidence of harassment for money was sufficient to attract Section 304B IPC. The recovery of the body from the car and failure of the accused to explain circumstances of death were emphasised. Reliance was placed on circumstantial evidence and Section 106 CrPC.

H) RELATED LEGAL PROVISIONS

i. Section 304B IPC
ii. Section 113B Evidence Act
iii. Sections 313, 378, 386 CrPC

I) JUDGEMENT 

The Supreme Court held that Section 304B IPC requires strict proof of four elements, including unnatural death and cruelty soon before death. The prosecution failed to establish these foundational facts. The alleged demand of Rs. 10 lakhs was found riddled with irreconcilable contradictions among witnesses.

The Court applied the principles laid down in Anant Chintaman Lagu v. State of Bombay for poisoning cases and found that none of the three essential tests were satisfied. Forensic evidence conclusively ruled out poisoning, and medical opinion supported a natural cause of death.

The High Court was found to have improperly substituted its view without demonstrating perversity in the Trial Court’s findings, contrary to settled law in Ghurey Lal v. State of Uttar Pradesh and Chhotan Sao v. State of Bihar.

The presumption under Section 113B Evidence Act was held inapplicable as the prosecution failed to prove cruelty linked to dowry demand soon before death.

a) RATIO DECIDENDI

Conviction under Section 304B IPC cannot be sustained unless unnatural death and dowry-related cruelty soon before death are proved beyond reasonable doubt. Statutory presumption under Section 113B Evidence Act arises only after discharge of foundational burden by the prosecution.

b) OBITER DICTA

The Court cautioned against routine reversal of acquittals in dowry death cases and emphasised judicial restraint, especially where personal liberty is at stake.

c) GUIDELINES

i. Appellate courts must interfere with acquittals only for compelling reasons.
ii. Forensic and medical evidence must be given due primacy in poisoning cases.
iii. Presumptions under Section 113B cannot replace proof of essential ingredients.

J) CONCLUSION & COMMENTS

The judgment reinforces doctrinal clarity on dowry death jurisprudence. It balances societal concern against misuse of stringent provisions by reiterating evidentiary discipline. The ruling serves as a precedent on the limits of appellate interference and underscores that criminal conviction must rest on proof, not moral outrage.

K) REFERENCES

Important Cases Referred

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

• Ghurey Lal v. State of Uttar Pradesh, (2008) 10 SCC 450

• Chhotan Sao v. State of Bihar, (2014) 4 SCC 54

• Sharad Birdhichand Sarda v. State of Maharashtra, (1984) 4 SCC 116

Important Statutes Referred

• Indian Penal Code, 1860

• Indian Evidence Act, 1872

• Code of Criminal Procedure, 1973