Supreme Court Upholds Acquittal in Dowry Death Case, Explains Scope Of Interference In Appeals Against Acquittal

The Supreme Court has upheld the acquittal of five accused in a 1998 dowry death case from Punjab, citing unreliable and contradictory evidence. The bench of Justices Aravind Kumar and Sandeep Mehta dismissed the appeals filed by the State of Punjab against the 2014 Punjab and Haryana High Court judgment that had acquitted the accused.

Case Background:

The case relates to the death of Kuldeep Kaur, who suffered 85% burn injuries on August 24, 1998 and died three days later. Her husband Randhir Singh and four in-laws were initially convicted by the trial court in 2002 for murder. However, the High Court acquitted them in 2014, which was challenged by the state in the Supreme Court.

Key Legal Issues:

1. Reliability of dying declarations

2. Appreciation of evidence in appeals against acquittal

3. Contradictions in witness testimonies

Court’s Decision:

The Supreme Court dismissed the state’s appeals and upheld the acquittal of the accused, making the following key observations:

On Dying Declarations:

The court found significant contradictions in the two dying declarations of the deceased. Justice Mehta noted:

“From an overall appreciation of the evidence available on record, the following indisputable conclusions can be culled out: […] That there is no allegation whatsoever of the prosecution witnesses that the deceased was harassed or humiliated in the matrimonial home on account of any demand of dowry, etc.”

The court held that the first dying declaration recorded by a police officer (Exhibit PM) appeared to be a “post-investigation document manufactured with an aim to falsely implicate the accused”.

On Evidence Appreciation:

The bench emphasized the limited scope of interference in appeals against acquittal, stating:

“If two views are possible, one favourable to the accused and the other favourable to the prosecution, the former would prevail. An interference with the judgment of acquittal is only permissible if the same suffers from patent illegality, perversity or misreading of the evidence available on record.”

On Witness Testimonies:

The court found several contradictions in the statements of key prosecution witnesses, including the victim’s sister and brother. Justice Mehta observed:

“Apparently thus, the evidence of Guddi(PW-4) to the extent, she claimed to have seen the victim in a burnt condition at her matrimonial home is false and cooked up.”

Conclusion:

The Supreme Court concluded that the High Court had rightly interfered with the trial court’s conviction, stating:

“The impugned order dated 17th July, 2014 rendered by the Division Bench of the High Court is based on an apropos appreciation of evidence available on record and hence, does not warrant any interference in these appeals against acquittal preferred by the State of Punjab.”

Case Details:

– Criminal Appeal Nos. 660-661 of 2015

– Appellant: State of Punjab

– Respondents: Randhir Singh & Others

– Judges: Justice Aravind Kumar and Justice Sandeep Mehta

– Appellant’s Counsel: Shri Vivek Jain, Deputy Advocate General

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