Gujarat High Court

Absence of continuous cruelty or specific dispute renders conviction for abetment of suicide unsustainable.

STATE OF GUJARAT vs PRAFULLABEN W/O MOHANBHAI RAMESHVARLAL PANDEY

Gujarat High CourtJUDGMENT: June 22, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The deceased, Jyotiben, married the respondent’s son in 1995. On 28.02.2010, after being rebuked by her mother-in-law (the respondent) for asking to accompany the family to Bikaner, the deceased self-immolated by pouring kerosene

Source reference: p. 1-2

The Trial Court acquitted the respondent on 20.09.2012, citing a lack of evidence regarding cruelty or property disputes

Source reference: p. 2

The State appealed this acquittal, arguing that the Trial Court failed to appreciate the dying declaration and circumstances leading to the suicide

Source reference: p. 3-4
02

Issues

1. Whether the Trial Court was justified in passing the judgment of acquittal based on the available evidence

Source reference: para. 10(1)

2. Whether the prosecution proved the charges under Sections 498(A) and 306 of the IPC beyond reasonable doubt

Source reference: para. 10(4)

3. Whether there is any manifest illegality or perversity in the Trial Court’s appreciation of evidence

Source reference: para. 10(3)
03

Law Applied

Section 498(A) of the IPC regarding cruelty by relatives and Section 306 of the IPC concerning abetment of suicide

Source reference: p. 1-2

principle of "double presumption of innocence" in acquittal appeals, where the initial presumption is reinforced by the Trial Court's verdict

Source reference: para. 12

standards for appellate interference in acquittals as established in Chandrappa v. State of Karnataka (2007) and Rajesh Prasad v. State of Bihar (2022), which state that if two reasonable conclusions are possible, the appellate court should not disturb the acquittal

Source reference: para. 14-15
04

Reasoning

The High Court observed that neither the FIR (Exh. 26) nor the dying declaration (Exh. 22) contained allegations of property disputes or prior physical/mental cruelty during the 14-year marriage

Source reference: para. 11-11.1

The dying declaration merely indicated a singular incident where the mother-in-law asked for ticket fare to Bikaner, which hurt the deceased's feelings but did not legally constitute "cruelty" or "abetment"

Source reference: para. 11.1

the prosecution failed to prove any continuous harassment or a specific act intended to provoke suicide, the High Court held that the Trial Court’s findings were a "possible view" and not perverse

Source reference: para. 11.2-16
05

Holding

The High Court dismissed the appeal and confirmed the judgment of acquittal

It held that the prosecution miserably failed to prove the charges beyond reasonable doubt and that the Trial Court's appreciation of evidence was cogent and lawful

Source reference: para. 17

The respondent’s bail bond was ordered to be cancelled

Source reference: para. 18
Gujarat High Court

Original Court PDF

STATE OF GUJARATvsPRAFULLABEN W/O MOHANBHAI RAMESHVARLAL PANDEY

Gujarat High Court · June 22, 2026

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