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Naresh Kumar v. State of Haryana

Criminal Appeal · Neutral citation not assigned (Criminal Appeal No. 1266 of 2013)Decided 14 Nov 2014
Criminal Appeal No. 1266 of 2013
Justice T.S. Thakur · Justice Adarsh Kumar Goel · Justice R. Banumathi

Background

Rekha Rani died from burns within ten months of marrying Naresh Kumar. Her father and other relatives described repeated dowry demands and harassment immediately before her death, including her return to her parents and her husband taking her back under threat of divorce. The High Court upheld his conviction but acquitted his mother and brother.

Decision Breakdown

The Supreme Court dismissed the husband's appeal and upheld his seven-year rigorous-imprisonment sentence for dowry death. The consistent evidence established a live connection between dowry harassment and the death, satisfying the requirement that harassment occur soon before death and triggering the statutory presumption. A suicide note asking that nobody be blamed was not conclusive when read alongside her expressions of helplessness and the other evidence. The relatives' acquittals did not require his acquittal because the evidence and responsibilities relevant to his conduct were different. He was directed to surrender to serve the remaining sentence.

Lesson Learnt

A general statement in a suicide note does not by itself defeat proved evidence of recent dowry harassment. Acquittal of some family members also does not erase a separately established case against the husband.

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

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