Absence of Proved Dowry Demands and Medical Evidence of Third-Party Involvement Negate Presumption of Dowry Death

The State appealed the acquittal of the deceased’s husband and in-laws (Respondents) regarding charges under Sections 498A/304B/34 of the IPC.

Komal Tyagi (deceased) married Vijay Tyagi on May 11, 2011, and was found dead at her paternal home on July 21, 2011, with both wrists slit.

The prosecution alleged the Respondents harassed her for dowry, specifically demanding a Hyundai Accent over a Maruti Alto and an additional Rs. 2,00,000/-.

However, the Hyundai Accent was booked on March 18, 2011—weeks before the marriage venue was confirmed or cards were printed—contradicting the father's claim of being "compelled" after card distribution.

Medical evidence revealed the deceased had old bruises (12-24 hours prior to death) while at her parents' house.

The trial court acquitted the Respondents on January 24, 2018, citing material contradictions and medical impossibility of self-inflicted wounds.

Whether the prosecution established the foundational facts of dowry-related cruelty "soon before death" to trigger the statutory presumption under Section 113B of the Evidence Act.

Whether the medical and circumstantial evidence supported the theory of suicide or pointed toward the involvement of a third party at the paternal home.

The court applied Section 304B of the IPC (Dowry Death), which requires death within seven years of marriage and proof of cruelty related to dowry demands "soon before death".

It read this alongside Section 113B of the Indian Evidence Act (Presumption as to dowry death), noting that the presumption only arises once the prosecution proves the foundational facts of harassment.

The court also relied on *State of Punjab v. Iqbal Singh*, emphasizing the need for firm action against dowry death while requiring a link between cruelty and death.

The court also relied on *State of Uttarakhand v. Sanjay Ram Tamta*, establishing that appellate courts should not interfere with acquittals unless the findings are perverse.

The High Court found the prosecution's narrative riddled with "material contradictions".

Document evidence from Deep Hyundai and the MCD proved the car was booked before the marriage ceremonies, falsifying the Complainant’s claim of coercion due to card distribution.

Medically, Dr. B.N. Mishra (PW-13) testified that once the tendons of one wrist were completely severed (Injury No. 2), it was "physically impossible" for the deceased to hold a blade and slit the second wrist, suggesting third-party involvement.

Furthermore, the blade was found *lying over* the pool of blood rather than under it, implying it was placed there after the bleeding occurred.

The court noted the "unnatural conduct" of the family members (PW-2, PW-3 & PW-4), who admitted they did not attempt to bandage the wounds or call the police, despite the deceased being alive and writhing in pain when discovered.

Finally, the fact that the deceased was wearing 34 pieces of jewelry at her parents' home negated the claim that she was being harassed for Rs. 2,00,000/- by her in-laws.

It held that the prosecution failed to prove the essential ingredients of Section 304B IPC, as there was no reliable evidence of dowry harassment "soon before death".

The medical evidence cast "grave suspicion" on the family's version, and the chain of circumstantial evidence was broken.

The Respondents' bail bonds and surety bonds were ordered to be discharged.