Patna High Court
Criminal LawCriminal Procedure and Evidence

An acquittal cannot be reversed unless the evidence compels an irresistible conclusion of guilt.

Meera Devi @ Meera Kumari vs The State of Bihar

Patna High CourtJUDGMENT: October 13, 20262 MIN READSOURCE JUDGMENT
An acquittal cannot be reversed unless the evidence compels an irresistible conclusion of guilt.. Meera Devi @ Meera Kumari vs The State of Bihar. Patna High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The appellant complained that her husband assaulted her abdomen while she was pregnant, causing bleeding and miscarriage, and that he and his family had also harassed her over a dowry demand.

Source reference: paras. 3–5, 9; pp. 2–6

The trial court convicted the husband under Section 498A IPC but acquitted him of offences under Sections 494 and 313 IPC and Sections 3 and 4 of the Dowry Prohibition Act.

Source reference: paras. 3–5, 9; pp. 2–6

In her appeal against acquittal, the appellant relied principally on her testimony and medical documents, supported by evidence from a hospital compounder.

Source reference: paras. 10–11; pp. 7–8
02

Issues

1. Whether the evidence established beyond reasonable doubt that the husband caused the appellant’s miscarriage by assault, so as to warrant interference with his acquittal under Section 313 IPC.

Source reference: paras. 10–15; pp. 7–10

2. Whether the acquittal under Sections 3 and 4 of the Dowry Prohibition Act warranted appellate interference.

Source reference: paras. 2, 12, 15–16; pp. 1, 8–10
03

Law Applied

The appeal concerned Section 313 IPC, which criminalises causing a woman with child to miscarry without her consent, subject to the statutory requirements of that offence, and Sections 3 and 4 of the Dowry Prohibition Act, concerning giving or taking dowry and demanding dowry, respectively.

Source reference: para. 2; p. 1

The Court applied the settled principle governing appeals against acquittal: an appellate court should not interfere unless the evidence supports an irresistible conclusion of guilt; the judgment cited no specific precedent for that principle.

Source reference: para. 15; p. 10
04

Reasoning

The Court found that the complainant’s account was not sufficiently corroborated to establish that an assault caused the miscarriage. The prescription was not proved through its author, the treating doctor was not examined, and the compounder’s evidence did not inspire confidence; no injury report established abdominal injury.

Source reference: paras. 12–15; pp. 8–10

In light of these evidentiary deficiencies and the applicable restraint in an appeal against acquittal, the Court found no basis to disturb the trial court’s findings. It did not separately analyse the evidence relating to the Dowry Prohibition Act charges.

Source reference: paras. 12–16; pp. 8–10
05

Holding

The Court dismissed the appeal and left undisturbed the acquittal under Section 313 IPC and Sections 3 and 4 of the Dowry Prohibition Act.

It stated that it had made no comment on the husband’s conviction under Section 498A IPC, which was the subject of a separate appeal, and directed that the records be sent with that appeal.

Source reference: paras. 17–18; p. 10
06

Acts & Sections Cited

8 provisions across 3 statutes referred to in this judgment. Each provision opens on LawLens.

Dowry Prohibition Act, 19612

Code of Criminal Procedure, 19731

Patna High Court

Original Court PDF

Meera Devi @ Meera KumarivsThe State of Bihar

Patna High Court · October 13, 2026

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