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Jatinder Kumar v. The State of Haryana

Criminal Appeal · 2019 INSC 1381Decided 17 Dec 2019
Criminal Appeal No. 1850 of 2010
Justice Deepak Gupta · Justice Aniruddha Bose

Background

The appellant's wife, Meenakshi, died by consuming poison within months of her marriage, after her family alleged repeated dowry demands (for a car and later for extending the appellant's clinic) and cruelty during her stay at her matrimonial home. The trial court convicted the appellant, his mother, and two brothers; the High Court acquitted the mother and brothers but upheld the appellant's conviction under Sections 304-B and 498-A (while setting aside his conviction for abetment of suicide under Section 306). The appellant challenged his conviction before the Supreme Court.

Decision Breakdown

The Supreme Court held that the consistent testimony of the deceased's father and uncle established both a dowry demand and cruelty connected to it, triggering the presumption of dowry death under Section 113-B of the Evidence Act. It rejected the appellant's reliance on Appasaheb v. State of Maharashtra (which held mere demands for financial help don't count as "dowry"), noting that a later three-judge bench decision in Rajinder Singh v. State of Punjab had overruled that narrow interpretation and clarified that "soon before death" does not mean "immediately before." The Court also rejected the argument that acquittal of the co-accused (who lived separately and did not benefit from the demanded money) meant the appellant should also be acquitted, since the High Court had given a reasoned basis for treating him differently as the sole beneficiary of the dowry demands. The appeal was dismissed, the conviction and sentence upheld, and the appellant's bail cancelled with a direction to surrender within four weeks.

Lesson Learnt

A demand for money dressed up as "financial assistance" (e.g., for a vehicle or a business) can still legally count as a dowry demand if connected to the marriage, and family members living separately and not benefiting from the demand can be acquitted even while the principal accused who directly benefited is convicted on the very same evidence.

Official source (sci.gov.in)View Judgment (PDF)

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