Absence of prior dowry complaints and evidence of matrimonial cohabitation precludes conviction for dowry death.

The appellant/complainant challenged the acquittal of the respondents (the deceased’s husband and in-laws) by the Second Additional Sessions Judge, Sihora, in Sessions Trial No. 100396/2014.

The deceased, Rani alias Parvati, married accused Monu Kachhi on 17.02.2014.

It was alleged that the accused demanded ₹1,00,000 in dowry and subjected her to cruelty.

On 01.05.2014, while attending a family marriage, the deceased reportedly left with her husband on a motorcycle and did not return.

Her body was found the next day on a railway track.

The prosecution charged the accused under Sections 120-B, 302, 304-B, 498-A, and 34 of the IPC, and Sections 3/4 of the Dowry Prohibition Act.

The medical opinion indicated the death was likely accidental, caused by being run over by a train.

1. Whether the prosecution proved beyond reasonable doubt that the deceased was subjected to dowry-related cruelty soon before her death to attract the statutory presumption under Section 304-B of the IPC.

2. Whether the trial court’s judgment of acquittal was perverse or based on a manifest error of law requiring interference by the High Court.

The court applied Section 304-B (Dowry Death) and Section 498-A (Cruelty) of the Indian Penal Code, 1860, alongside Sections 3 and 4 of the Dowry Prohibition Act.

Regarding the appellate power to interfere with acquittals, the court relied on the principle from Ganesha v. Sharanappa & Anr. (2014) 1 SCC 87, reaffirmed in Mahabir and Others v. State of Haryana (2025), which mandates that interference is only permissible in "exceptional cases" involving manifest errors of law or the overlooking of clinching material evidence.

The Court observed that the marriage lasted only a few months, during which the deceased stayed with her in-laws for only two brief periods (three days and eight days respectively).

Crucially, testimonies from the parents (PW-2 and PW-3) admitted that no dowry was demanded at the time of marriage or the farewell ceremony.

Although allegations of a ₹1,00,000 demand were made after her death, the family admitted they never lodged a police complaint or convened a community panchayat during the two months the deceased resided at her parental home prior to the incident.

The Court found that the allegations of dowry harassment appeared to be an afterthought triggered by the distress of her death.

Furthermore, the medical evidence (PW-19) and expert opinion (Ex. P/37) suggested the death was accidental/suicidal (train run-over) rather than homicidal.

The Court concluded that the material contradictions in witness testimonies, as identified by the trial court, rendered the prosecution’s case insufficient for conviction.

The Court answered the issues in the negative, finding no grounds to invoke the statutory presumption of dowry death given the lack of credible evidence regarding harassment "soon before death".

The appeal was dismissed, and the acquittal of the respondents was upheld.