The Supreme Court of India has set aside the conviction of a father-in-law under Section 498A of the Indian Penal Code (IPC), observing that the prosecution failed to establish the charge of dowry demand through independent evidence. The Bench, comprising Justices Aravind Kumar and N.V. Anjaria, ruled that it is “unsafe” to rely on the contradictory statements of interested witnesses when key allegations like dowry demands are omitted in initial police statements.
The Court was presiding over three criminal appeals arising from a judgment of the High Court of Madhya Pradesh. The High Court had previously acquitted the husband, father-in-law, and mother-in-law of murder charges (Section 302 IPC) but upheld their conviction for cruelty (Section 498A IPC).
Background of the Case
The deceased tied the matrimonial knot with Nagendra Singh on July 12, 2000. On April 15, 2001—within nine months of the marriage—she sustained fatal burn injuries in her matrimonial kitchen. The prosecution alleged that she was subjected to cruelty over dowry demands, specifically a car. It was claimed that her husband stuffed cloth in her mouth, poured kerosene, and set her on fire.
Two dying declarations were recorded. The first, by an Executive Magistrate, implicated the in-laws in setting her ablaze. The second, by a Deputy Superintendent of Police, suggested suicide, with the victim stating she set herself on fire due to domestic quarrels.
Arguments of the Parties
Appellant Narendra Singh (Father-in-law): He contended that the allegations were generic and that the first dying declaration was result of tutoring by the parents. He highlighted that he had rendered 32 years of government service and his dismissal following conviction would cause “irreparable loss” regarding retirement benefits. He argued the family’s testimonies were filled with material contradictions.
The State and De-facto Complainant: They challenged the acquittal under Section 302 IPC, arguing that the first dying declaration was uninfluenced and free from concoction. They asserted that the death occurred within nine months of marriage, triggering the presumption under Section 113B of the Evidence Act.
Court’s Analysis and Observations
The Court scrutinized the evidence and identified several infirmities in the prosecution’s narrative:
- Contradictory Dying Declarations: The Bench noted the existence of two conflicting declarations. Referring to the first declaration, the Court observed: “In the cross-examination, the Tehsildar has deposed that there were about 4-5 persons who were there with the deceased in the hospital, and one of them had told the deceased to depose in a certain way… This casts a shadow of doubt on the veracity of the dying declaration.”
- Omissions in Police Statements: The Court found that the family members (PW-1 to PW-5) had not mentioned dowry demands in their initial Section 161 CrPC statements. The Bench remarked: “A fact as important as demand of dowry that was so traumatic so as to lead to a death of a young lady could not have been left out of the statement… at the first blush.”
- Lack of Independent Witnesses: The Court noted that neighbours (PW-7 to PW-9) turned hostile and suggested cordial relations. One neighbour (PW-10) even provided an alibi for the parents-in-law, stating they were on a walk at the time of the incident.
- Misuse of Section 498A: The Court cautioned against the tendency to rope in all family members. It observed: “It seems that the father-in-law was roped in the present matter by an extension of roping the husband… as is the case in certain S. 498A matters.”
Regarding the letter (Ex. P-3) allegedly written by the deceased, the Court found it of “little evidentiary value” as it was not proved by a handwriting expert.
The Decision
Citing the ‘Panchsheel’ principles of circumstantial evidence from Sharad Birdhichand Sarda v. State of Maharashtra, the Court held that if two inferences are possible, the one favouring the accused must be accepted.
The Court concluded: “In such a scenario it becomes unsafe for the Court to rely on contradictory statements of the interested witnesses… the demand of dowry was not proved.”
While the Supreme Court dismissed the appeals filed by the State and the victim’s brother seeking conviction for murder, it allowed the appeal of the father-in-law, setting aside his conviction under Section 498A IPC.
Case Details
- Case Title: Narendra Singh v. The State of Madhya Pradesh (and connected appeals)
- Case No.: Criminal Appeal No. 302 of 2014
- Bench: Justice Aravind Kumar and Justice N.V. Anjaria
- Date: April 30, 2026
