Dowry Death Case: Supreme Court Restores Acquittal in Poisoning Allegations

This case involves an appeal by the appellants, Sandeep Kumar and Others, against the judgment of the High Court of Uttarakhand, which overturned their acquittal under Section 304B of the Indian Penal Code (IPC) and sentenced them to life imprisonment. The case revolves around the tragic death of the appellant’s wife, Priyanka, and the charge of dowry death in connection with her alleged poisoning. The Supreme Court had to decide whether the High Court’s reversal of the acquittal was justified, given the circumstances and evidence presented.

Background of the Case

The appellants were charged with the offense of dowry death under Section 304B of the IPC after Priyanka, their daughter-in-law, died on January 23, 2011. Priyanka’s father, the complainant, alleged that his daughter was tortured for dowry by the appellants, and that they had demanded a sum of Rs. 10 lakhs. The complainant further claimed that his daughter was poisoned, which led to her death. An FIR was lodged, and the investigation revealed that no external injury was found on Priyanka’s body, and the cause of death was determined to be poisoning. The appellants were initially acquitted by the Sessions Court of Haridwar, but the High Court reversed the acquittal and convicted them under Section 304B IPC. The appellants appealed the decision in the Supreme Court.

Petitioner’s Arguments

The appellants, through their counsel Shri Siddharth Dave, put forth the following arguments in support of their appeal:

• Absence of Poisoning Evidence: The appellants argued that there was no concrete evidence to prove that the death was caused by poisoning. The post-mortem report did not indicate any external injuries, and no poison was found in the viscera. The appellants contended that the prosecution failed to establish the cause of death as poisoning.
• Contradictory Testimonies: The appellants pointed out the contradictions in the testimonies of the prosecution witnesses, particularly regarding the alleged demand for dowry and the circumstances of Priyanka’s death. They emphasized that there was no consistent evidence linking the appellants to the demand for dowry or her subsequent death.
• Exaggeration of Dowry Demand: The appellants claimed that the demand for Rs. 10 lakhs made by the first appellant was not a dowry demand but rather a request for financial assistance for house construction, which the deceased’s family had agreed to pay back. They argued that such requests could not be classified as dowry demands.
• Post-Mortem and Medical Evidence: The appellants challenged the findings of the post-mortem, claiming that the medical evidence did not support the claim of poisoning. They also criticized the investigation for failing to consult the treating doctors who could have provided crucial information regarding the deceased’s health conditions.

Respondent’s Arguments

The respondents, representing the State of Uttarakhand, put forth the following counterarguments:

• Evidence of Poisoning: The respondents contended that the prosecution had provided ample evidence that Priyanka’s death was due to poisoning. They pointed out that the internal organs of the deceased were congested, which could be indicative of poisoning, even though the actual poison was not identified in the viscera.
• Harassment and Dowry Demand: The respondents emphasized that the appellants had tortured Priyanka for dowry and that the deceased had made several calls to her parents, expressing fear for her life due to the financial pressure imposed on her. The respondents argued that the demand for Rs. 10 lakhs was a clear indication of dowry harassment.
• Circumstantial Evidence: The respondents referred to the circumstantial evidence that linked the appellants to the crime. They highlighted the recovery of the deceased’s body from the car, and the fact that the appellants had failed to provide a satisfactory explanation for the circumstances surrounding her death. The respondents argued that this pointed to a clear case of dowry death under Section 304B IPC.

Supreme Court’s Analysis

The Supreme Court carefully examined the arguments and evidence presented by both parties:

• Evaluation of Evidence: The Court noted the absence of direct evidence connecting the appellants to the poisoning. While the medical evidence suggested congestion of internal organs, the Court also recognized that this could be caused by other factors, such as food poisoning or tuberculosis, as suggested by the defense.
• Demand for Dowry: The Court acknowledged the discrepancies in the testimonies regarding the demand for dowry. The testimonies of PW1, PW2, and PW3 were inconsistent, and the Court found it difficult to rely solely on their statements. The Court also noted that no formal complaint about dowry harassment had been lodged before the incident, and the evidence on dowry demands was not compelling.
• Circumstantial Evidence: The Court discussed the circumstantial evidence presented by the prosecution, including the recovery of the body from the car. However, the Court emphasized that this evidence, by itself, did not conclusively prove the appellants’ involvement in the death. The Court further noted that the appellants had taken the deceased to the hospital when her condition worsened, which was inconsistent with the behavior of someone who had committed a crime.
• Application of Section 304B IPC: The Court examined the ingredients of Section 304B IPC, which requires proof of dowry harassment and an unnatural death within seven years of marriage. The Court found that while there was some evidence of harassment, it was not sufficient to establish that the death was a dowry death under the provisions of Section 304B.

Supreme Court’s Judgment

The Supreme Court ruled in favor of the appellants, setting aside the High Court’s judgment and restoring the acquittal by the Sessions Court. The Court held:

“The prosecution has failed to establish the cause of death beyond a reasonable doubt. There is no evidence of poisoning, and the demand for dowry is not proven to the satisfaction of the Court. The appeal is allowed, and the judgment of the High Court is set aside.”

The Court also remarked that:

“The acquittal by the Sessions Court should not have been overturned without substantial and compelling reasons. In this case, the evidence is insufficient to prove the guilt of the appellants.”

Conclusion

The Supreme Court’s ruling underscores the importance of clear and convincing evidence in criminal trials, particularly in cases involving serious allegations such as dowry death. The decision reflects the Court’s careful consideration of the evidence and its commitment to upholding the principles of justice, even in cases where there are significant contradictions in the testimonies and medical evidence. The judgment also reinforces the principle that the acquittal of the accused should not be overturned lightly, especially in the absence of compelling reasons and where the evidence is inconclusive.

Petitioner Name: Sandeep Kumar.
Respondent Name: State of Uttarakhand.
Judgment By: Justice Rohinton Fali Nariman, Justice K.M. Joseph, Justice Aniruddha Bose.
Place Of Incident: Uttarakhand.
Judgment Date: 02-12-2020.

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