Bombay High Court

Acquittal affirmed where inconsistent witness testimonies fails to establish cruelty and abetment of suicide beyond reasonable doubt.

The State Of Maharashtra vs Parasharam Laxman Bhandurge And Anr.

Bombay High CourtJUDGMENT: June 18, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The deceased married Accused No. 1 in 1996.

Source reference: para. 4

For four years, the couple resided with the victim's father (Complainant), during which Accused No. 1 worked as a tractor driver.

Source reference: para. 5

The prosecution alleged that Accused No. 1, addicted to alcohol, harassed and beat the deceased to compel her father to provide a new tractor or transfer ownership of his existing tractor to him.

Source reference: para. 6

In April 2005, the victim was reported missing and was subsequently found dead in a well; the medical report cited "asphyxia due to drowning" as the cause of death.

Source reference: para. 8

The Trial Court acquitted the husband and mother-in-law of charges under Sections 498A and 306 r/w 34 of the IPC, citing inconsistent evidence.

Source reference: para. 11

The State appealed this acquittal.

Source reference: para. 1
02

Issues

1. Whether the prosecution established through reliable evidence that the accused subjected the victim to cruelty within the meaning of Section 498A of the IPC.

Source reference: para. 11

2. Whether the actions of the accused constituted abetment of suicide under Section 306 of the IPC.

Source reference: para. 11

3. Whether the findings of the Trial Court were perverse or suffered from a misreading of evidence justifying interference by the Appellate Court.

Source reference: para. 28
03

Law Applied

Section 498A (cruelty by husband or relatives) and Section 306 (abetment of suicide) of the Indian Penal Code.

Source reference: para. 1

Appellate principles established in Babu Sahebagouda Rurdragoudar Ors. v. State of Karnataka, which restrict interference in acquittals unless there is patent perversity or a misreading of material evidence.

Source reference: para. 28

H.D. Sundara v. State of Karnataka, emphasizing that if two reasonable views exist, the appellate court must not overturn an acquittal simply because it favors an alternative view.

Source reference: para. 29
04

Reasoning

The Court found significant discrepancies in the prosecution's evidence. While the Complainant (PW-3) alleged continuous harassment for a tractor during their stay at his house, the neighbor (PW-5) testified that the victim never complained during that period.

Source reference: para. 24

PW-3 also provided contradictory statements regarding whether the victim resided at her matrimonial home or with him during those four years.

Source reference: para. 25

The testimonies of the Complainant and the mediator (PW-4) regarding a past attempt to pacify the accused were inconsistent.

Source reference: para. 26

The Court noted a lack of synchronicity between the eyewitness accounts of the recovery of the body and the official police records regarding timing and procedure.

Source reference: paras. 22-23

Consequently, the Court determined that the prosecution failed to establish a direct nexus between the alleged harassment and the suicide.

Source reference: para. 27
05

Holding

The Court held that the Trial Court’s view was a "possible view" and lacked perversity; the prosecution failed to provide reliable evidence of cruelty or abetment beyond a reasonable doubt.

The High Court dismissed the State's appeal and upheld the Judgment and Order of acquittal dated 25th May 2006.

Source reference: paras. 30-31
Bombay High Court

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The State Of MaharashtravsParasharam Laxman Bhandurge And Anr.

Bombay High Court · June 18, 2026

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