Tarabai v. The State of Maharashtra
Background
Krishnabai married in May 1989 and went to live with her husband's family, where her mother-in-law (the appellant, Tarabai) and sister-in-law allegedly subjected her to repeated cruelty and dowry demands for not bringing enough gold, cash, and new clothes. Krishnabai's mother visited multiple times and witnessed mistreatment firsthand. On 23 March 1990, within a year of the marriage, Krishnabai was found dead in her marital home with 100% burn injuries. Both the mother-in-law and sister-in-law were convicted by the trial court; the Bombay High Court later acquitted the sister-in-law but upheld the mother-in-law's conviction.
Decision Breakdown
The Supreme Court dismissed Tarabai's appeal, rejecting each of her arguments in turn. It found no real delay in filing the FIR given that the family first rushed Krishnabai to hospital and only filed the report after the post-mortem confirmed the cause of death; it found no merit in the claim that a torn, unsigned draft statement undermined the prosecution's case; and it held that the mother's evidence was credible and consistent. Because Krishnabai died of unnatural causes within seven years of marriage amid evidence of dowry-related cruelty, the statutory presumption under Section 113-A of the Evidence Act (read with Sections 304-B and 498-A IPC) operated against the accused. The Court also noted that the best witness to rebut the allegations, the appellant's own husband, was never called by the defence. It upheld the conviction and the seven-year sentence.
Lesson Learnt
Where a woman dies an unnatural death within seven years of marriage and there is evidence of dowry-related cruelty beforehand, the law presumes the death was a dowry death unless the accused can convincingly rebut it, and failing to produce an obviously relevant defence witness can itself count against the accused.