Supreme Court Upholds Acquittal of Father-in-Law in Dowry Death Case Under IPC Sections 302, 304B, 498A, and 201 Due to Insufficient Evidence and Failure to Prove Marriage Date

Criminal Law-- Indian Penal code, 1860- Sections  302, 304B, 498A and 201-- Code of criminal Procedure, 1973- Sections 174 and 378-- Evidence Act, 1872- Section 106-- Deceased married to accused no.2- Accused no.1 was father in law of deceased-lady-- Deceased died- Accused no.1 posed that the deceased died due to electrocution while ironing the clothes-- Accused no.1 himself filed a report -- Inquiry-- Case u/s 302, 498A, 193 and 201 of IPC registered-- Father-in law- Accsued no.1 and husband accused no.2 were convicted by session court-- Appeal preferred by convicted accused before High court-- High was pleased to set a side conviction and acquitted both the accused- Aggrieved state filed an appeal against acquittal before session court-- Appeal against acquittal of accused no.2 already dismissed by suprement court- Case rest on circumstantial evidence-- Burden of proof-- Dead body of deceased was found in the house of accused and that it self one of the additional link in the chain of circumstances-- Death of deceased was homicidal death-- Ligature mark found on the neck of deceased which supporting the case of strangulation-- False report given by accused no.1 father in law-- Accused no.1 was present in the house at the time of incident-- No independent witnesses were examined-- Father, mother, and uncle of the deceased deposed that the deceased was subjected to cruelty and harassment for the dowry-- Deamd of dowry-- Unnatural death of deceased-- Presence of accused no.1 establised-- Medical evidence supported the case of prosecution-- Accused no.1 failed to discharge the burden in support of his case of innocense-- Fit case to reverse the judgment of acquittal- Acquittal set aside- Appeal allowed

Para- 12, 13, 14, 16, 17, 18, 19, 20, 21, 22

The Supreme Court dismissed the State's appeal against the acquittal of Janved Singh, father-in-law of the deceased Pushpa, for offences under Sections 302, 304B, 498A, and 201 of the Indian Penal Code, 1860 (IPC) -- The Court held that the prosecution failed to establish the marriage date, a crucial element for Section 304B IPC, and the evidence did not form a complete chain of circumstances implicating the respondent -- The testimonies of related witnesses were recorded belatedly, diminishing their credibility, and there was no evidence of the respondent's presence or motive at the time of death -- Applying principles from Sharad Birdhichand Sarda v. State of Maharashtra, the Court emphasized that circumstantial evidence must be consistent only with the guilt hypothesis -- The judgment underscores the prosecution's burden to prove all ingredients beyond reasonable doubt and the high threshold for interfering with acquittals