In a significant ruling, the Supreme Court of India has acquitted Karan Singh, who was convicted by the trial court and the Punjab and Haryana High Court for dowry death under Section 304-B and Section 498-A of the Indian Penal Code (IPC). The apex court observed that trial courts are repeatedly making errors in dowry death cases, failing to adhere to established legal principles, and relying on moral convictions rather than strict evidentiary standards.
The bench comprising Justice Abhay S. Oka and Justice Ujjal Bhuyan set aside the conviction and directed State Judicial Academies to take corrective measures to train trial judges in handling dowry death cases with due regard to the essential ingredients of the law.
Case Background
Karan Singh was accused of subjecting his wife, Asha Rani, to cruelty and harassment for dowry, leading to her alleged suicide by hanging on April 2, 1998, less than two years after their marriage on June 25, 1996. The prosecution claimed that there was repeated demand for dowry, including Rs. 60,000 for purchasing a jeep, a motorcycle, refrigerator, and mixi, among other items.
The Sessions Court convicted Singh, sentencing him to seven years of rigorous imprisonment under Section 304-B IPC (dowry death) and one year under Section 498-A IPC (cruelty by husband). The Punjab and Haryana High Court upheld the conviction, following which the appellant moved the Supreme Court.
Legal Issues and SC’s Observations
The Supreme Court scrutinized the evidence and found several inconsistencies in the prosecution’s case. The primary legal question revolved around the application of Section 304-B IPC, which defines dowry death and mandates that:
1. The death must have occurred under unnatural circumstances within seven years of marriage.
2. The deceased must have been subjected to cruelty or harassment soon before her death.
3. The cruelty or harassment must be for or in connection with dowry demands.
The court observed that while the death occurred within seven years of marriage, there was no clear and reliable evidence proving that the deceased was subjected to harassment or cruelty ‘soon before her death’. The Supreme Court also noted significant omissions and contradictions in witness testimonies, particularly from the mother (PW-6) and brother (PW-7) of the deceased.
Key Observations by the Supreme Court:
– “Section 304-B of the IPC was brought on the statute book in 1986. This Court has repeatedly laid down and explained the ingredients of the offence under Section 304-B. But, the Trial Courts are committing the same mistakes repeatedly.”
– “Unless the prosecution proves that the deceased was subjected to cruelty or harassment for or in connection with dowry soon before her death, the presumption under Section 113-B of the Indian Evidence Act cannot be invoked.”
– “Perhaps this is a case of moral conviction rather than legal conviction.”
The court criticized the trial court for convicting the accused despite the absence of solid legal evidence and highlighted the urgent need for State Judicial Academies to step in and provide proper training to trial judges on the correct application of dowry death laws.
Errors in Trial Court’s Conviction
The Supreme Court found that the prosecution failed to prove any act of cruelty by Karan Singh ‘soon before the death’, which is a mandatory requirement under Section 304-B IPC. While witness testimonies mentioned past dowry demands and alleged harassment, there was no direct evidence of ill-treatment in the immediate period leading up to the suicide.
Moreover, the inconsistencies in statements given to the police at different times raised serious doubts about the credibility of the allegations. The Court pointed out that many of the claims regarding dowry demands were not part of the initial police statements and were introduced only in subsequent supplementary statements, suggesting an afterthought.
In light of these findings, the Supreme Court ruled that the conviction was legally unsustainable and acquitted Karan Singh of all charges.
