Featured image for Supreme Court Judgment dated 05-09-2018 in case of petitioner name State of Madhya Pradesh vs Shriram & Anr.
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Dowry Death Acquittal: Supreme Court Overturns Conviction in Suicide Case

The Supreme Court of India, in the case of State of Madhya Pradesh vs. Shriram & Anr., examined whether a woman’s suicide shortly after marriage was caused by cruelty and harassment by her in-laws. The case involved charges under Sections 498-A and 306 of the Indian Penal Code (IPC), along with Section 113-A of the Indian Evidence Act, which presumes abetment of suicide in cases of cruelty.

The Supreme Court upheld the High Court’s decision to acquit the accused, emphasizing the lack of substantial evidence of cruelty or harassment.

Background of the Case

The case revolved around the death of Sarita Bai, who married Respondent No.1 on 23 April 1998. According to the prosecution:

  • After marriage, Sarita Bai was allegedly harassed and tortured by her husband and mother-in-law.
  • On 14 July 1998, Sarita Bai committed suicide by consuming poison at her in-laws’ house.
  • The police charged the accused under Sections 498-A (cruelty), 304-B (dowry death), and 306 (abetment of suicide).
  • The Trial Court convicted the accused, sentencing them to three years’ imprisonment under Section 498-A and five years under Section 306.

The accused appealed to the Madhya Pradesh High Court, which overturned the conviction, leading to the present appeal before the Supreme Court.

Arguments of the Petitioner (State of Madhya Pradesh)

The State of Madhya Pradesh, representing the prosecution, argued:

  • The deceased faced constant harassment for dowry and was pressured to bring a bigger vehicle as part of dowry.
  • Witnesses (PW-2 and PW-3) testified that the accused used to taunt the deceased and demand dowry.
  • Since the deceased committed suicide within three months of marriage, a presumption under Section 113-A of the Evidence Act should be drawn against the accused.
  • The Trial Court correctly convicted the accused based on witness testimonies and circumstantial evidence.

Arguments of the Respondents (Accused)

The accused argued:

  • The Trial Court wrongly presumed guilt without substantial evidence.
  • PW-2 and PW-3 made inconsistent and contradictory statements.
  • The deceased never complained about physical torture or dowry harassment before her death.
  • The medical report did not indicate any physical injuries on the deceased.

High Court’s Decision

The Madhya Pradesh High Court set aside the conviction, ruling that:

  • The Trial Court made assumptions without concrete evidence.
  • No direct evidence proved that the deceased was subjected to cruelty or harassment.
  • The presumption under Section 113-A of the Evidence Act could not be applied due to lack of proof.
  • The statements of PW-2 and PW-3 were contradictory and unreliable.

Supreme Court’s Observations

The Supreme Court closely examined the evidence and highlighted key findings:

  • “There is no cogent or positive evidence to prove that the respondents subjected the deceased to mental or physical cruelty or harassment, so as to force her to commit suicide.”
  • “The prosecution failed to establish the guilt of the accused beyond a reasonable doubt.”
  • “Witness testimonies contained contradictions and improvements made during cross-examination.”
  • “A conviction under Section 498-A or 306 IPC requires clear evidence of cruelty, which is absent in this case.”

Final Judgment

The Supreme Court dismissed the appeal, confirming the acquittal of the accused. The Court ruled:

“The presumption under Section 113-A of the Indian Evidence Act cannot be drawn against the respondents in the absence of credible evidence. The prosecution failed to prove cruelty or harassment leading to suicide.”

Impact of the Judgment

This judgment clarifies important legal principles:

  • Mere suicide of a woman in her matrimonial home does not automatically prove abetment by the husband or in-laws.
  • The prosecution must present clear and direct evidence of cruelty or harassment.
  • Presumptions under Section 113-A of the Evidence Act require strong supporting evidence.
  • Courts must carefully scrutinize witness statements to avoid wrongful convictions.

With this ruling, the Supreme Court reaffirmed that criminal convictions must be based on solid evidence, ensuring that no one is punished without proof beyond a reasonable doubt.


Petitioner Name: State of Madhya Pradesh.
Respondent Name: Shriram & Anr..
Judgment By: Justice N.V. Ramana, Justice Mohan M. Shantanagoudar.
Place Of Incident: Madhya Pradesh.
Judgment Date: 05-09-2018.

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