Acquittal in Abetment of Suicide Confirmed Where Allegations of Household Disputes Disprove Cruelty and Instigation

The State appealed the acquittal of the respondents (mother-in-law and sister-in-law) of the deceased, Chandrikaben Baraiya.

The prosecution alleged that on March 11, 2010, the accused harassed the deceased over household chores, leading her to commit suicide by self-immolation.

The deceased suffered 95%–98% burns and succumbed to her injuries after giving a Dying Declaration (DD).

The Trial Court (Addl. Sessions Judge, Rajkot) acquitted the accused on December 16, 2011, noting insufficient evidence of cruelty or instigation.

The High Court reviewed the medical evidence and witness testimonies to determine if the acquittal was perverse.

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

2. Whether the prosecution proved beyond reasonable doubt that the accused instigated or harassed the deceased to meet the ingredients of Sections 498(A) and 306 of the IPC.

3. Whether the Dying Declaration and medical evidence were reliable given the extent of the deceased's burn injuries.

The Court applied Section 306 of the IPC regarding abetment of suicide, read with Section 107 (instigation) and Section 498(A) regarding cruelty by husband or relatives.

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

Precedents cited for the scope of appellate review include Chandrappa v. State of Karnataka [(2007) 4 SCC 415], Rajesh Prasad v. State of Bihar [(2022) 3 SCC 471], and Ramesh v. State of Karnataka [[2024] 9 SCC 169], establishing that an appellate court should not disturb an acquittal if two reasonable views are possible.

The Court observed that the primary allegations involved "quarrels regarding household work," which do not meet the legal threshold for "cruelty" under Section 498(A) or "instigation" under Section 306.

The medical evidence from PW-5, PW-8, and PW-9 revealed the deceased had 95%–98% burns; the Court found it highly improbable that the IO could obtain a signature if no part of the body escaped burns, casting doubt on the DD’s reliability.

Furthermore, the panch witnesses turned hostile, and family witnesses (PW-7) failed to provide evidence of ill-treatment.

The Court determined that since the marriage had subsisted for seven years with three children and no prior history of serious harassment was proven, the Trial Court’s view was a "possible" and "reasonable" conclusion.

The bail bonds were cancelled, and the court reaffirmed that appellate interference is unwarranted unless the lower court's approach is vitiated by glaring mistakes.