Wife’s Suicide: Madras HC Upholds Husband And Mother-in-Law’s Acquittal, Finding Cruelty And Abetment Unproved

The appellant, the deceased woman’s father and de facto complainant, challenged the acquittal of her husband and mother-in-law on a charge under Section 306 IPC.

The prosecution alleged that they suspected the deceased’s character, prevented her from attending college, refused to pay her fees and mistreated her; she died by suicide on 4 July 2015, less than a year after her marriage.

The trial court acquitted both accused, finding that cruelty driving the deceased to suicide had not been proved.

On appeal, the father relied, among other things, on the deceased’s death within seven years of marriage and Section 113-A of the Evidence Act.

Section 306 IPC requires proof of suicide and abetment; abetment entails the accused’s intention and involvement in aiding or instigating the suicide, with a live link or nexus between the conduct and the suicide.

The Court relied on Gurcharan Singh v. State of Punjab, (2017) 1 SCC 433, including its direction to assess whether cruelty induced the suicide and its caution that ordinary domestic discord or a victim’s hypersensitivity, without the necessary abetment, does not establish the offence.

Section 113-A of the Evidence Act permits—not automatically requires—the court to presume abetment where a married woman commits suicide within seven years of marriage and the statutory condition of cruelty is established, having regard to all the circumstances; Section 106 concerns facts especially within a person’s knowledge.

The appeal also required consideration of whether the trial court’s acquittal rested on plausible findings or was perverse.

The Court found that the principal allegations were weakened by the father’s initial complaint, which stated that the deceased and the accused were living happily and that the accused were taking proper care of her; the witnesses did not adequately explain their subsequent change of account.

The alleged refusal to pay college fees was not established: the deceased continued attending college, the friend did not corroborate the allegation, and the investigation did not verify the fees issue with the college.

Other alleged incidents were uncorroborated, vague or did not establish that the accused had caused them.

The Court therefore found no proved cruelty sufficient to support the Section 113-A presumption and no evidence of the intention or involvement necessary for abetment under Section 306 IPC.

The accused’s statement to the doctor about an accidental fall did not alter the result, as the prosecution did not allege that they had caused the death; the Court likewise found the cited authority concerning a death caused by the accused distinguishable.

Since the trial court’s reasons were plausible and not perverse, appellate interference was unwarranted.

It dismissed the appeal and confirmed the acquittal of respondents 2 and 3 in S.C. No. 324 of 2017.