In a significant ruling, the Supreme Court of India has upheld the conviction of a husband accused in a dowry death case, despite his claims of innocence. The judgment delivered by a bench comprising Justice C.T. Ravikumar and Justice Sanjay Karol, reaffirmed the decision of the Allahabad High Court, which had reversed an earlier acquittal by the trial court.
Background of the Case
The case dates back to the tragic death of a woman who was found dead under mysterious circumstances due to 100% burn injuries on September 1, 1994, at her matrimonial home in Azamgarh, Uttar Pradesh. She had married the accused in 1988, and after a traditional ‘Gauna’ ceremony in 1992, she moved in with her husband. The incident occurred just two years after she began living with her husband, within seven years of their marriage—a critical timeframe under Indian law when it comes to dowry-related deaths.
Initially, her death was treated as an accident, and her body was cremated on the same day. However, suspicions arose, leading to the registration of an FIR nearly two months later, on October 20, 1994, at the Jeeanpur Police Station in Azamgarh. The case was registered as Crime No. 348 of 1994, leading to a trial (Session Trial No. 484 of 1995) that resulted in the acquittal of the husband and another accused by the trial court.
Legal Issues and Arguments
The primary legal issues in the case revolved around Sections 304B and 498A of the Indian Penal Code, which pertain to dowry deaths and cruelty by a husband or his relatives, respectively. The prosecution alleged that the woman had been subjected to cruelty and harassment related to dowry demands, which ultimately led to her death.
The defence, represented by senior advocate Mr. Rajbir Bansal and his team, argued that the FIR was lodged with considerable delay and that there was no evidence of dowry demands or harassment prior to her death. They contended that the High Court had improperly appreciated the evidence, particularly the testimony of key witnesses.
On the other hand, the State of Uttar Pradesh, represented by advocate Ms. Srishti Singh, argued that the High Court had meticulously re-evaluated the evidence after the Supreme Court remanded the case back for reconsideration. The State emphasized that the burden of proof had shifted to the husband under Section 113B of the Indian Evidence Act, 1872, to explain the circumstances leading to her death, particularly since it occurred within the matrimonial home.
Supreme Court’s Observations and Judgment
In its detailed judgment, the Supreme Court noted that the death had occurred within seven years of her marriage and under suspicious circumstances, involving 100% burn injuries while she was in her matrimonial home. The Court observed that the evidence provided by prosecution witnesses, including family members of the deceased, established a consistent pattern of cruelty and harassment.
One of the key aspects of the judgment was the application of Sections 113B and 106 of the Indian Evidence Act. The Court highlighted that once the prosecution established the foundational facts—such as the timing of the death in relation to the marriage and the nature of the death—the burden shifted to the husband to disprove the allegations. The Court found that he had failed to provide any explanation for how she sustained the burn injuries, especially given that he was present in the same room but remained unharmed.
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Quoting from the judgment, the bench stated, “When the prosecution has discharged its burden and proved such facts, the onus was on the appellants in terms of the provisions under Section 113B of the Evidence Act to establish that it was not a dowry death.” The Court further noted that the husband’s silence and lack of an explanation under Section 313 of the Criminal Procedure Code (CrPC) were telling.
The Supreme Court concluded that the High Court had rightly reversed the trial court’s acquittal, finding no perversity in the appreciation of evidence. It dismissed the appeal, thereby upholding the 10-year rigorous imprisonment under Section 304B and 3 years under Section 498A of the IPC.
