Madras HC Acquits Husband, Mother-In-Law In Dowry-Death Case, Finding Dowry-Demand Testimony Unreliable Amid Dispute Over Baby’s Hospital Visit

The first appellant, Karthik V, married the deceased, Priyanka, on 8 June 2017.

The prosecution alleged that he and his mother, the second appellant, subjected Priyanka to cruelty over demands for additional gold, including shortly before her death by suicide on 8 December 2018.

The trial court convicted both appellants under Sections 498-A and 304-B IPC.

On appeal under Section 374(2) CrPC, the appellants challenged the reliability of the dowry allegations, relying on inconsistencies and improvements in the witnesses’ accounts, the RDO’s report, and the delay in forwarding the FIR to the Magistrate.

The High Court independently assessed the evidence, including the testimony of the deceased’s parents and relatives, the RDO’s report, and the circumstances surrounding the FIR.

Section 498-A IPC criminalises a husband’s or relative’s cruelty to a married woman.

Section 304-B IPC applies where a woman’s death occurs otherwise than under normal circumstances within seven years of marriage and she was subjected, soon before her death, to cruelty or harassment for or in connection with a dowry demand.

Under Section 113-B of the Indian Evidence Act, the statutory presumption of dowry death arises when the prosecution establishes the foundational facts required by Section 304-B.

The prosecution must prove its case beyond reasonable doubt; the RDO’s report is not by itself determinative, and the court must independently assess the evidence.

No judicial precedents are cited in the judgment.

The Court found that the evidence did not reliably establish dowry-related cruelty soon before the death.

The deceased’s parents acknowledged that the appellants had made no direct dowry demand to them; the other relatives were largely hearsay witnesses, and several prosecution witnesses made material improvements not reflected in their earlier accounts to the RDO.

The RDO’s report was not treated as conclusive, but its findings were consistent with the evidentiary weaknesses identified by the Court.

The delayed forwarding of the FIR, together with the police’s earlier knowledge of the death, further supported the possibility of deliberation before the complaint was lodged.

The evidence also made it reasonably possible that the immediate trigger was a quarrel over taking the child to hospital, rather than dowry-related harassment.

The prosecution therefore failed to establish the necessary basis for the convictions or the statutory presumption under Section 113-B.

It allowed the appeal, set aside the trial court’s judgment and sentence, and acquitted both appellants of all charges.

Any fine paid was ordered to be refunded, and any bail bonds executed were discharged.