Munni Devi v. State of Uttar Pradesh
Background
A pregnant woman died by suicide within a year of marriage; her mother-in-law was convicted of dowry death and causing an unborn child's death, though she had already been acquitted of cruelty and specific dowry-demand charges.
Decision Breakdown
The Supreme Court held a 304-B conviction requires proof the accused specifically subjected the woman to cruelty tied to a dowry demand: general, collective family allegations aren't enough. With no individualized evidence against the mother-in-law (who wasn't even present at the death), and given her earlier acquittal on cruelty, the conviction could not stand.
Lesson Learnt
Courts cannot convict a family member in a dowry-death case merely because a demand was made in the household: specific, individualized evidence of cruelty by that person is required.