Statutory presumptions under Sections 113A and 113B require foundational proof of cruelty or harassment.

Meenaben, daughter of the complainant, married accused Ravindrabhai Kantilal Chauhan on 27.05.2003.

The prosecution alleged that after marriage she was subjected to taunts, demands for money, physical and mental cruelty, and harassment for not having a male child by her husband and in-laws.

On 10.05.2007, she died by suicide by hanging from a ceiling fan.

An FIR was registered for offences under Sections 306, 498A and 114 of the IPC and Sections 3 and 7 of the Dowry Prohibition Act.

The Trial Court examined eight prosecution witnesses and acquitted all accused.

The complainant and the State challenged the acquittal before the High Court.

The appeals abated against respondent Nos. 2 and 3 and survived only against Ravindrabhai, respondent No. 1.

Whether the Trial Court erred in acquitting the accused of offences under Sections 306, 498A and 114 of the IPC and Sections 3 and 7 of the Dowry Prohibition Act?

Whether the prosecution established, through reliable evidence, cruelty, harassment, instigation or abetment having a proximate nexus with Meenaben’s suicide?

Whether the statutory presumptions under Sections 113A and 113B of the Indian Evidence Act could be invoked in the absence of foundational evidence of cruelty, harassment or dowry-related conduct?

Whether the High Court, in an appeal against acquittal, was justified in interfering with the Trial Court’s findings under the principles governing appellate review?

The Court applied Sections 306 and 498A read with Section 107 of the IPC, requiring proof of abetment, instigation or intentional conduct amounting to cruelty with a proximate nexus to the suicide.

Sections 3 and 7 of the Dowry Prohibition Act were also considered in relation to the alleged dowry demands.

The Court held that presumptions under Sections 113A and 113B of the Indian Evidence Act cannot arise unless the prosecution first establishes foundational facts through cogent and reliable evidence of cruelty, harassment or dowry-related conduct.

On appeals against acquittal, the appellate court may reappreciate the evidence, but must respect the reinforced presumption of innocence and should not interfere where two reasonable views are possible; interference is warranted only where the Trial Court’s conclusions are perverse or manifestly erroneous.

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, (2024) 8 SCC 149; and Ramesh v. State of Karnataka, (2024) 9 SCC 169.

The High Court found that the principal prosecution witnesses, particularly the complainant and his son, gave materially contradictory and inconsistent evidence regarding their relationship with Naginbhai, a police employee and relative, and other surrounding circumstances.

The post-mortem doctor found no external or internal injuries, while material witnesses cited by the prosecution, including the deceased’s mother and younger brother, were not examined.

The evidence also failed to establish any specific incident of cruelty, harassment, instigation or quarrel proximate to the suicide.

Consequently, the foundational facts necessary for invoking Sections 113A and 113B of the Evidence Act were absent.

The Court further held that the husband’s disagreement with the deceased’s proposed beauty-parlour course, particularly when their infant child was reportedly unwell, did not by itself constitute cruelty, provocation, instigation or abetment.

In view of these evidentiary deficiencies and the double presumption of innocence applicable in an appeal against acquittal, the Trial Court’s view was held to be reasonable and not perverse.

It held that the prosecution failed to prove beyond reasonable doubt that Ravindrabhai had subjected Meenaben to legally cognisable cruelty or had abetted, instigated or provoked her suicide.

The presumptions under Sections 113A and 113B of the Evidence Act were therefore unavailable.

Both appeals were dismissed, and the Trial Court’s judgment of acquittal was confirmed.

The bail bond was cancelled, and the record and proceedings were directed to be returned to the Trial Court.