Conviction for cruelty or abetment of suicide requires credible proof of specific acts constituting harassment or instigation.

Padminiben, sister of the complainant, was married to accused No.1 and resided with him. The prosecution alleged that, as she was unable to conceive, the accused subjected her to mental and physical harassment, which ultimately drove her to commit suicide by hanging on 25 May 2010.

An accidental-death entry was initially registered, and the complainant lodged the criminal complaint approximately 22 days after the incident alleging offences under Sections 498A, 306 and 114 of the Indian Penal Code. After investigation, a charge-sheet was filed and the Sessions Court framed charges against the accused. The prosecution examined witnesses and produced documentary evidence, but the trial Court acquitted all accused. The State preferred the present appeal under Section 378(1) and (3) of the Code of Criminal Procedure, 1973.

1. Whether the trial Court was justified in acquitting the accused of the offences punishable under Sections 498A, 306 and 114 of the IPC

2. Whether the trial Court properly appreciated the oral and documentary evidence led by the prosecution

3. Whether the impugned judgment of acquittal suffered from any illegality, irregularity, perversity or manifest error warranting appellate interference

The Court applied Sections 498A and 306 of the IPC, which respectively require proof of cruelty by the husband or his relatives and abetment of suicide; Section 107 of the IPC defines abetment through instigation, conspiracy or intentional aid, while Section 114 concerns the liability of an abettor present when the offence is committed.

The Court held that a conviction under these provisions requires credible proof of a specific act or omission amounting to cruelty, instigation, incitement or intentional aid connected with the suicide.

On appeals against acquittal, the Court relied on Chandrappa v. State of Karnataka, (2007) 4 SCC 415; Rajesh Prasad v. State of Bihar, (2022) 3 SCC 471; Babu Sahebagouda Rudragoudar v. State of Karnataka, AIR 2024 SC 2252; and Ramesh v. State of Karnataka, (2024) 9 SCC 169, reiterating that although an appellate court may fully reappreciate the evidence, the accused enjoy a strengthened or “double” presumption of innocence, and an acquittal should not be disturbed where two reasonable views are possible unless the trial Court’s view is perverse or manifestly illegal.

The High Court found that the prosecution proved only the fact of an unnatural death, while failing to establish the essential ingredients of cruelty or abetment. The complaint was lodged about 22 days after the suicide, and no contemporaneous complaint of harassment had been made during the approximately fifteen-year marriage.

The evidence indicated cordial relations between the families, and the deceased and accused No.1 resided separately from accused Nos. 2 and 3. The prosecution witnesses, including the complainant’s family members, did not materially support the prosecution case, no independent neighbours were examined, and the medical evidence established the unnatural death but disclosed no incriminating circumstance linking the accused to it.

In these circumstances, the evidence did not prove any specific act of instigation, incitement, intentional aid or legally cognizable cruelty. Applying the restricted appellate approach applicable to acquittals and the rule that reasonable doubt must benefit the accused, the Court held that the trial Court’s assessment was neither perverse nor legally unsustainable.

The appeal was dismissed, the trial Court’s judgment and order of acquittal were confirmed, the accused’s bail bonds were cancelled, and the record and proceedings were directed to be returned to the trial Court.