Supreme Court Quashes Dowry Death Case Due to Lack of Evidence Against Accused Relatives

The Supreme Court of India recently delivered a crucial judgment in Mirza Iqbal @ Golu & Anr. vs. State of Uttar Pradesh & Anr., quashing criminal proceedings against the brother-in-law and mother-in-law of a woman who allegedly died by suicide due to dowry harassment. The Court ruled that there was no specific evidence against the accused and that the allegations were vague and generalized. This case highlights the judicial approach towards false dowry cases and the importance of protecting innocent family members from undue harassment.

Background of the Case

The case originated from a complaint filed by Nisar Ullah, the father of the deceased, Rushda Nisar. Rushda was married to Mirza Ismail Beg on December 25, 2015. The complainant alleged that Rushda faced continuous dowry demands from her husband and his family. Specifically, he claimed that the accused demanded a four-wheeler and Rs.10,00,000 in cash. When these demands were not met, the deceased was allegedly harassed and beaten.

According to the complainant, on July 24, 2018, the accused persons, including her husband, brother-in-law Mirza Iqbal alias Golu, mother-in-law Sammi alias Shamima Bano, and sister-in-law Hifza alias Chinki, assaulted her and ultimately hanged her. The complainant arrived at the scene from Surat and, upon seeing his daughter’s condition, lodged an FIR at Kotwali Police Station, Gorakhpur, under the following charges:

Section 304-B IPC (Dowry Death)
Section 498-A IPC (Cruelty by Husband and Relatives)
Sections 323, 504, and 506 IPC (Causing Hurt, Intentional Insult, Criminal Intimidation)
Sections 3 and 4 of the Dowry Prohibition Act, 1961

Proceedings Before the High Court

Mirza Iqbal and Shamima Bano approached the Allahabad High Court under Section 482 CrPC, seeking to quash the chargesheet against them. The High Court, however, dismissed their plea and directed them to surrender before the trial court and apply for bail.

Arguments Before the Supreme Court

Petitioners’ (Mirza Iqbal & Shamima Bano) Arguments:

The brother-in-law, Mirza Iqbal, was a bank employee working at ICICI Bank, Khalilabad, which is 40 km away from Gorakhpur. He was at work on the day of the incident, as proven by attendance records and CCTV footage.
Shamima Bano, the mother-in-law, was living with Mirza Iqbal at Khalilabad since 2017 and was not present at the scene.
The complaint was filed with vague and general allegations against the entire family, which is a common pattern in dowry-related cases.
There was no direct evidence linking them to the alleged offense.

Respondents’ (State & Complainant) Arguments:

The deceased had suffered harassment over dowry demands.
As per the postmortem report, she died of asphyxia due to hanging.
The accused family members were directly responsible for her death.
The trial should proceed to determine the actual involvement of all accused.

Supreme Court’s Observations

The Supreme Court examined the evidence and noted the following:

There were no specific allegations against the brother-in-law and mother-in-law.
The complaint contained generalized accusations against all family members, which the Court found to be an abuse of legal process.
The accused had provided documentary evidence, including work records and residence proof, establishing that they were not present at the crime scene.
The Court referenced Geeta Mehrotra & Anr. vs. State of U.P., where it had previously ruled that in the absence of specific allegations, family members should not be unnecessarily dragged into criminal trials.

Final Judgment

The Supreme Court ruled as follows:

The criminal proceedings against Mirza Iqbal and Shamima Bano were quashed.
The chargesheet filed in FIR No. 136 of 2018 at PS-Kotwali, Gorakhpur was set aside.
The Court reiterated that in dowry-related cases, family members should not be implicated without substantial proof.

Key Takeaways

Protection of Innocent Family Members: The ruling reinforces that vague and general allegations against in-laws cannot be the basis for a criminal trial.
Burden of Proof in Dowry Cases: The prosecution must establish clear and direct involvement of each accused, rather than making blanket accusations.
Judicial Safeguards Against Misuse of Law: The case highlights the Court’s responsibility to prevent misuse of legal provisions meant to protect women from dowry harassment.
Time and Resources of Judiciary: The judgment discourages frivolous cases that clog the judicial system and waste resources.

This ruling provides significant relief to family members wrongfully accused in dowry cases while ensuring that genuine cases continue to be prosecuted with due diligence.

Petitioner Name: Mirza Iqbal @ Golu & Anr..
Respondent Name: State of Uttar Pradesh & Anr..
Judgment By: Justice R. Subhash Reddy, Justice Hrishikesh Roy.
Place Of Incident: Gorakhpur, Uttar Pradesh.
Judgment Date: 13-12-2021.

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