Featured image for Supreme Court Judgment dated 13-06-2019 in case of petitioner name State of Haryana vs Angoori Devi & Anr.
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Dowry Death Allegations: Supreme Court Acquits Accused Due to Lack of Evidence

The case of State of Haryana vs. Angoori Devi & Anr. is a significant ruling regarding dowry-related death and the necessity of strong evidence for conviction. The Supreme Court, in this case, upheld the Punjab and Haryana High Court’s decision to acquit the accused due to lack of sufficient proof linking the alleged dowry harassment to the victim’s death.

The case involved the tragic death of Babli, who was married to Kartar Singh (Respondent No.3). She allegedly suffered harassment for dowry before dying of burn injuries within seven years of marriage. The trial court had convicted the accused under Sections 498A and 304B of the Indian Penal Code (IPC), but the High Court overturned the conviction due to weak evidence. The State of Haryana challenged this decision before the Supreme Court.

Background of the Case

Babli was married to Kartar Singh, and her sister Neeru was married to his brother Pawan. The prosecution alleged that Babli’s in-laws harassed her for dowry and later set her on fire. The complaint was filed by Babli’s father, who stated that:

  • Babli was forced to leave her matrimonial home due to dowry demands.
  • She returned after a panchayat intervention but was later burned to death.
  • Her in-laws had demanded Rs. 60,000, a gold ring, and a chain.

Petitioner’s Arguments

The State of Haryana argued that:

  • The trial court had correctly convicted the accused based on the evidence provided by the victim’s family.
  • The victim had suffered continuous harassment and was eventually killed due to non-fulfillment of dowry demands.
  • The High Court erred in reversing the conviction, as the statements of the father and brother of the deceased were reliable.

Respondent’s Arguments

The accused, including the husband, mother-in-law, and father-in-law, contended that:

  • There was no direct evidence of harassment or demand for dowry.
  • The High Court rightly found inconsistencies in the statements of the prosecution witnesses.
  • The complainant’s younger daughter Neetu, who was allegedly an eyewitness, was never examined in court.
  • The victim’s sister, who was also married into the same family, did not allege any harassment, casting doubt on the prosecution’s claims.

Supreme Court’s Observations and Judgment

The Supreme Court examined the case carefully and observed:

“The High Court rightly found that the evidence did not show any proximate connection between the demand for dowry and the act of cruelty or harassment leading to the death.”

The Court emphasized the need for strong evidence to convict under Section 304B IPC, stating:

“To attract Section 304B of the Indian Penal Code, the prosecution has to establish that soon before the death, the deceased was subjected to cruelty and harassment in connection with demand for dowry.”

Since the prosecution failed to prove that Babli was harassed “soon before her death” for dowry, the Supreme Court upheld the High Court’s decision to acquit the accused.

Key Legal Precedents Considered

The Supreme Court referred to several past rulings:

  • Shanti vs. State of Haryana (1991) 1 SCC 371: Established that a conviction under Section 304B IPC requires proof of cruelty linked to dowry.
  • Bachni Devi vs. State of Haryana (2011) 4 SCC 427: Held that courts must carefully scrutinize evidence in dowry death cases.
  • Baijnath vs. State of Madhya Pradesh (2017) 1 SCC 101: Stressed the need for clear evidence of dowry harassment soon before the death.

Final Ruling and Impact

The Supreme Court ruled:

  • The prosecution failed to establish cruelty related to dowry soon before the victim’s death.
  • The statements of the complainant and his son were based on hearsay.
  • The non-examination of crucial witnesses, such as the victim’s younger sister, weakened the prosecution’s case.
  • The High Court’s acquittal was justified.

This ruling reiterates that dowry-related deaths require strong and proximate evidence linking the accused’s actions to the death of the victim. The decision sets a precedent ensuring that wrongful convictions do not occur due to weak evidence.

Conclusion

The Supreme Court’s ruling in this case reinforces the necessity of proving a direct link between dowry harassment and the victim’s death for conviction under Section 304B IPC. While dowry-related violence remains a grave concern, the judgment highlights the importance of ensuring that convictions are based on substantial and credible evidence rather than assumptions or hearsay.


Petitioner Name: State of Haryana.
Respondent Name: Angoori Devi & Anr..
Judgment By: Justice Indira Banerjee, Justice Ajay Rastogi.
Place Of Incident: Haryana, India.
Judgment Date: 13-06-2019.

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