Dowry Death Case: Supreme Court Acquits Accused in Girish Singh vs. State of Uttarakhand
The case of Girish Singh vs. State of Uttarakhand revolved around allegations of dowry harassment and cruelty leading to the suicide of the appellant’s wife. The Supreme Court was called upon to decide whether the High Court had correctly convicted the accused under Section 304B of the Indian Penal Code (IPC), reversing the trial court’s acquittal.
Girish Singh and his father, Jodh Singh, were accused of torturing the deceased for dowry and subjecting her to severe harassment, leading to her suicide by self-immolation. The prosecution claimed that the deceased was harassed for not bringing a television and VCR as dowry. The trial court had acquitted the accused, but the High Court overturned this verdict and sentenced them to seven years of rigorous imprisonment.
Arguments of the Petitioner
The defense argued that the High Court had wrongfully convicted the accused by relying on contradictory witness statements. The petitioners contended:
“No case is made out under Section 304B read with Section 34 of the IPC. The High Court ignored the fact that the prosecution witnesses were unreliable and contradicted their own previous statements.”
The defense further highlighted:
- The prosecution witnesses had altered their testimonies in court, deviating from their initial statements under Section 161 CrPC.
- Several letters written by the deceased’s father contained no allegations of dowry harassment.
- There was evidence that the deceased was influenced by supernatural beliefs, and religious ceremonies were conducted for her mental well-being.
Arguments of the Respondent
The State of Uttarakhand, representing the prosecution, supported the High Court’s decision, stating:
“There was sufficient evidence to justify the conviction, including testimonies from family members of the deceased confirming harassment and dowry demands.”
The prosecution claimed:
- Witnesses testified that the deceased was repeatedly harassed for a television and VCR as dowry.
- The father-in-law allegedly made inappropriate advances towards the deceased, adding to her distress.
- There was evidence of continued cruelty towards the deceased before her suicide.
Supreme Court’s Verdict
The Supreme Court, with Justices K.M. Joseph and Sanjay Kishan Kaul presiding, overturned the High Court’s conviction, restoring the trial court’s acquittal. The Court observed:
“The foremost aspect to be established by the prosecution is that there was reliable evidence to show that the woman was subjected to cruelty or harassment by her husband or his relatives, which must be for or in connection with any demand for dowry, soon before her death. Before the presumption is raised, it must be established that the woman was subjected to cruelty or harassment and it is not any cruelty that becomes the subject matter of the provision but it is the cruelty or harassment for or in connection with, demand for dowry.”
The Court emphasized:
- There were contradictions in the prosecution witnesses’ testimonies.
- Letters written by the deceased’s father did not mention dowry harassment.
- The trial court had reasonably acquitted the accused, and the High Court erred in reversing this decision without substantial evidence.
Key Takeaways from the Judgment
- Convictions under Section 304B IPC require clear evidence linking harassment to dowry demands.
- Presumptions under dowry death provisions must be supported by strong evidence.
- Contradictions in witness statements can weaken the prosecution’s case.
- Appellate courts must exercise caution before overturning acquittals.
This judgment reinforces the principle that courts must carefully assess evidence before presuming guilt in dowry death cases.
Petitioner Name: Girish Singh.
Respondent Name: State of Uttarakhand.
Judgment By: Justice K.M. Joseph, Justice Sanjay Kishan Kaul.
Place Of Incident: Uttarakhand.
Judgment Date: 23-07-2019.
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