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Criminal LawSupreme Court of India

Maya Devi & Anr. v. State of Haryana

Criminal Appeal · Neutral citation not assigned (Criminal Appeal No. 1263 of 2011)Decided 7 Dec 2015
Criminal Appeal No. 1263 of 2011
Justice Vikramajit Sen · Justice R.K. Agrawal

Background

A woman married in July 1994 died by poisoning at her matrimonial home in Rohtak in September 1996. Her family said she had been repeatedly harassed over dowry demands. The trial court convicted her husband and mother-in-law, and the High Court reduced the sentence for dowry death to ten years' rigorous imprisonment and dismissed the appeal. The defence argued that she suffered from depression and took her own life, and that the mother-in-law was working in Delhi at the time.

Decision Breakdown

The Court dismissed the appeal and upheld the convictions. It held that a death within seven years of marriage, caused otherwise than under normal circumstances and preceded by cruelty connected with dowry demands, is a "dowry death" under Section 304B whether it was suicide, homicide or accident, because the section does not depend on how the death occurred. Once the essential facts are proved, Section 113B requires the court to presume that the accused caused the death, and the burden shifts to them to rebut that presumption. The Court relied on the family's evidence of repeated demands, the doctor's testimony that she had confided in him about harassment by her in-laws, and the mother-in-law's dominant role in the demands, even though she was not living in the house.

Lesson Learnt

When a married woman dies in unnatural circumstances within seven years of marriage, and there is proof of dowry-related harassment shortly before, the law presumes that her husband and in-laws caused the death, and they must prove otherwise. A later claim of suicide or an in-law's absence from the house does not by itself defeat that presumption.

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