Supreme Court Acquits Mother-in-Law in Alleged Dowry Death, Quashes Conviction Under Sections 304-B and 316 IPC

A bench of Justices J.K. Maheshwari and Atul S. Chandurkar heard the appeal filed by Munni Devi against her conviction for offences punishable under Sections 304-B and 316 of the Indian Penal Code. The appeal challenged concurrent findings that had earlier sustained her conviction for the alleged dowry death and causing death of a foetus; she had been sentenced to seven years’ imprisonment in the High Court order upheld in part from the trial court’s judgment.

The Court allowed the appeal, quashed the impugned High Court judgment and set aside the appellant’s convictions under Sections 304-B and 316 IPC, finding that the prosecution had not proved the necessary ingredients of those offences beyond reasonable doubt. The Court noted that conviction under Section 304-B required proof that the death was “caused otherwise than under normal circumstances within seven years of the marriage and that soon before the death, the victim was subjected to cruelty or harassment by her husband or any relative of her husband for or in connection with any demand for dowry.” The Court, in its reasoning, observed: “As per Section 304-B (1) it would be necessary for the prosecution to show that the death was caused otherwise than under normal circumstances within seven years of the marriage and that soon before the death, the victim was subjected to cruelty or harassment by her husband or any relative of her husband for or in connection with any demand for dowry. In the present case the death of the appellant’s daughter-in-law has occurred otherwise than under normal circumstances in view of the fact that it was a case of suicide. The death occurred within seven years of the marriage. It would therefore be necessary to examine whether any evidence has been led to prove beyond reasonable doubt that soon prior to committing suicide, the appellant’s daughter-in-law was subjected to cruelty or harassment by the appellant. This is for the reason that the appellant’s conviction is under Section 304-B of the Penal Code.” The Court further stated that “the prosecution has failed to prove the charges under Sections 304-B and 316 of the Penal Code against the appellant beyond reasonable doubt.”

Background

The prosecution case arose from the death by suicide on 03.08.2011 of Alka (also referred to as Pooja), who had married the appellant’s son Rahul on 02.12.2010. The informant, the deceased’s brother Anil Singh Tomar (PW-2), lodged an FIR alleging harassment and repeated demands of Rs. 2,00,000 and a car from the matrimonial home. The trial court convicted Rahul, his brother Chetan and their mother (the appellant) under Sections 498-A, 304-B and 316 IPC and under Sections 3 and 4 of the Dowry Prohibition Act, 1961, sentencing them to concurrent terms. The Allahabad High Court later acquitted Chetan and set aside certain convictions of Rahul (and reduced his sentence; his appeal before this Court later abated on his death), but it upheld the appellant’s convictions under Sections 304-B and 316 while acquitting her of Section 498-A and the Dowry Act offences.

On appeal to the Supreme Court, counsel for the appellant argued that the prosecution failed to establish specific instances of cruelty or harassment by the appellant, relying instead on general allegations and an unproduced registered complaint. Counsel for the State relied on the presumption under Section 113-B of the Evidence Act, contending that harassment shortly before death attracted the statutory presumption against relatives of the husband. The Court examined witness testimony and found deficiencies: as observed in the judgment, “Except for using the expression ‘mental and physical harassment’ the witness has not deposed about any specific instance narrated to him by the deceased that could indicate that his sister was subjected to cruelty or harassment specifically by the appellant.” Given the absence of specific evidence tying the appellant to cruelty or harassment in connection with a dowry demand, the Court concluded there was no basis to sustain the convictions under Sections 304-B and 316. The appeal was allowed, the impugned order dated 02.03.2021 was quashed and the appellant was acquitted and ordered to be released forthwith if not required in any other case; bail bonds, if any, stood discharged.

Case Details: Case No.: Criminal Appeal No. 532 of 2021 (2026 INSC 136) Case Title: Munni Devi v. State of Uttar Pradesh Appearances: For the Petitioner(s): Abhijit Banerjee, Advocate For the Respondent(s): Ruchira Goel, Advocate