The Supreme Court of India, in a notable judgment delivered by Justice C.T. Ravikumar and Justice Sanjay Kumar on October 21, 2024, acquitted an accused under Section 498-A of the Indian Penal Code (IPC), underscoring the perils of exaggerated allegations in dowry harassment cases. The court highlighted that mere familial relations should not be grounds for conviction without substantial evidence, emphasizing the need for fair trials and careful examination of claims in dowry-related cases.
The appeal arose from a 2011 case concerning the unnatural death of Renuka, the daughter of the second respondent, which led to the registration of FIR No. 87/11 at Wadala T.T. Police Station in Mumbai. The appellant, Yashodeep Bisanrao Vadode, who was related to the victim through marriage, was convicted under Section 498-A IPC by both the trial court and the Bombay High Court.
Background of the Case
Renuka was married to Rajesh Jagan Karote on December 11, 2008. The prosecution alleged that she faced dowry demands and harassment from her husband and his relatives, including the appellant. The demand for Rs. 5 lakhs for purchasing a flat under the MHADA scheme allegedly began in January 2010. Renuka’s death on April 16, 2011, led to multiple trials and convictions of family members, including Yashodeep, who married the victim’s sister-in-law in October 2010.
The appellant, who was initially convicted of dowry harassment under Section 498-A read with Section 34 IPC, challenged the judgment, arguing that there was no specific evidence linking him to the alleged cruelty. He contended that he was implicated merely due to his relation by marriage and not due to any direct act of harassment.
Key Observations of the Supreme Court
In overturning the conviction, the Supreme Court made important observations about the nature of dowry harassment cases. Justice C.T. Ravikumar, delivering the judgment, noted:
“It is a matter of common knowledge that exaggerated versions of the incident are reflected in a large number of complaints, and the tendency of over implication is also reflected in a significant number of cases.”
The court emphasized that convictions under Section 498-A IPC require clear evidence of cruelty aimed at extracting dowry or of a nature likely to drive a woman to suicide or cause grave harm. The judges criticized the lower courts for convicting the appellant despite the absence of direct evidence, noting:
– The appellant’s marriage into the family occurred only five months before the victim’s death, limiting his involvement in alleged dowry demands.
– No specific acts of cruelty were attributed to the appellant during the trial, and there was no prior complaint against him before Renuka’s death.
– The evidence presented by the prosecution lacked the substance necessary to connect the appellant to the allegations of dowry harassment.
The bench further referred to the Supreme Court’s decision in Preeti Gupta v. State of Jharkhand (2010), which cautioned against the broad and vague allegations often seen in dowry cases, stating:
“Courts must be vigilant to identify instances of over implication to prevent unjust suffering and irreparable consequences for those wrongly accused.”
Case Details
– Case Number: SLP (Crl.) No. 8245 of 2023
– Bench: The bench consisted of Justice C.T. Ravikumar and Justice Sanjay Kumar.
– Appellant: Yashodeep Bisanrao Vadode
– Respondents: The State of Maharashtra & Anr.
