Bride’s Suicide Four Months Into Marriage: Delhi HC Upholds Husband, Mother-In-Law’s Dowry-Death Convictions

Meena died by hanging approximately four and a half months after marrying appellant Sanjiv Saxena. Her family alleged that Sanjiv and his relatives subjected her to cruelty and harassment over demands for a motorcycle, cash, clothes, household articles and money for repairs.

The Trial Court convicted the appellants under Sections 498-A and 304-B read with Section 34 IPC, sentenced them to life imprisonment for dowry death, and acquitted them under Section 406 IPC.

On appeal, appellant No. 2’s appeal abated following his death.

The remaining appellants challenged, among other matters, the reliability of the witnesses’ testimony, omissions in their earlier statements, and the fairness of the investigation.

Section 304-B IPC applies where a woman dies otherwise than under normal circumstances within seven years of marriage and was subjected soon before death to cruelty or harassment by her husband or his relative in connection with a dowry demand; once these foundational facts are established, Section 113-B of the Evidence Act requires the court to presume that the accused caused the dowry death, subject to rebuttal.

“Dowry” bears the meaning assigned by Section 2 of the Dowry Prohibition Act, 1961.

Section 498-A IPC criminalises specified wilful conduct and harassment connected with unlawful demands.

Under Section 162 CrPC read with Section 145 of the Evidence Act, a police statement is not substantive evidence and may be used to contradict a witness only in the prescribed manner; omissions may amount to contradictions where legally significant.

Section 172(1) CrPC requires an investigating officer to maintain a case diary of investigative proceedings but does not require the officer personally to handwrite it; engagement of a scribe, without a statutory bar or demonstrated prejudice, does not by itself invalidate the investigation.

The Court accepted that Meena’s death by hanging was unnatural and occurred within seven years of marriage.

It found that PW-1’s account described repeated dowry-related demands and payments, including demands for a motorcycle, cash, festival articles and money for roof repairs, and that the alleged harassment continued within the short period preceding her death.

Although PW-1 and PW-2 were confronted with their initial statements to the SDM, the Court noted that they had referred to supplementary police statements and had not been confronted with those statements; the omissions in the initial statements therefore did not, in the circumstances, establish the asserted contradictions.

The Court treated the material omissions in the evidence of PW-3 and PW-6 with caution, but held that they did not displace the evidence of PW-1 and PW-2.

It also rejected the challenge based on scribes recording statements and case diaries because no prejudice or effect on investigative fairness was demonstrated.

The Court consequently found the necessary proximity between dowry-related cruelty and death established, triggering the Section 113-B presumption, which the defence had not rebutted.

It dismissed the appeal and upheld the convictions and sentences of Sanjiv Saxena and Bimla Saxena, directing them to surrender within two weeks to serve the remaining sentence.

Appellant No. 2’s appeal had abated on his death.