Dowry-death liability cannot extend to relatives absent evidence of their cruelty or harassment soon before death.

Soni Devi married appellant No. 1, Nityanand Tiwary, in 2008 and died at her matrimonial home on 29 December 2012.

Her father alleged that her husband demanded a motorcycle and Rs. 50,000, and that she was assaulted and harassed when the demands were not met.

The post-mortem recorded bruises and a fracture in the neck region, but the doctor could not determine the cause of death.

The Sessions Court convicted all four appellants under Sections 498A/34 and 304B/34 IPC and sentenced each to life imprisonment for the Section 304B offence, with concurrent sentences for Section 498A.

They appealed, challenging the evidence, proof of cause of death, and the findings of dowry-related cruelty.

Whether the prosecution established the ingredients of dowry death under Section 304B IPC against appellant No. 1, including unnatural death within seven years of marriage and dowry-related cruelty soon before death

Whether the evidence established the involvement of appellants Nos. 2–4 in dowry-related cruelty or harassment soon before the deceased’s death

Section 304B IPC applies where a woman dies from burns or bodily injury, or otherwise than under normal circumstances, within seven years of marriage, and was subjected soon before her death to cruelty or harassment by her husband or a relative of her husband in connection with a demand for dowry; the provision deems the husband or relative to have caused the dowry death

The Court identified these statutory ingredients as requiring proof of an unnatural death, death within seven years of marriage, and dowry-related cruelty or harassment soon before death

The appellants were also charged and convicted under Sections 498A/34 IPC

No judicial precedent was cited.

The Court found that the deceased died within seven years of her marriage and that the injuries recorded in the inquest and post-mortem supported the finding of an unnatural death, notwithstanding the doctor’s inability to identify its precise cause

The father’s evidence specifically attributed the demand for the remaining dowry and the associated assault and torture to appellant No. 1; the Court accepted this evidence as establishing dowry-related cruelty soon before death

By contrast, no witness attributed a recent demand or cruelty to appellants Nos. 2–4, and the deceased had not identified them as involved in that conduct

The Court therefore found the case established against the husband, but not against the other appellants.

The Court affirmed appellant No. 1’s convictions and sentences under Sections 498A/34 and 304B/34 IPC, but set aside the convictions and sentences of appellants Nos. 2–4 and discharged them and their bailers from their bail-bond liabilities