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The State of Uttarakhand v. Sanjay Ram Tamta @ Sanju @ Prem Prakash

Criminal Appeal · 2025 INSC 187Decided 11 Feb 2025
Criminal Appeal No. 112 of 2014
Justice B.R. Gavai · Justice K. Vinod Chandran

Background

A young bride, married barely six months, was found hanging in her matrimonial home. Her husband and in-laws were prosecuted for dowry death. The trial court convicted only the husband, relying on a presumption that unexplained scratch marks on the body indicated cruelty linked to a dowry demand, while acquitting the other family members for lack of proof they lived in the same household. The High Court went further and acquitted the husband too, holding that the family's modest financial and social status made the alleged demand of ₹4,00,000 and a house plot improbable.

Decision Breakdown

The Supreme Court agreed the death was suicidal, as confirmed by medical evidence, but noted that a suicidal death alone does not attract Section 304B: cruelty or harassment linked to a dowry demand "soon before" death must also be proved for the statutory presumption to apply. It found that the deceased's father and brother had not mentioned the dowry demand or physical torture in their original statements to police, and these details emerged only at trial, making them legally-treated contradictions. A key neighbour witness turned hostile and instead described a domestic quarrel unrelated to dowry. Since the demand for dowry itself was not established beyond reasonable doubt, the presumption under Section 113B of the Evidence Act never arose. The Court dismissed the State's appeal, upholding the acquittal, though for different reasons than the High Court gave.

Lesson Learnt

A conviction for dowry death requires proof of every statutory ingredient, including cruelty or harassment connected to a dowry demand shortly before death, and testimony about such a demand that is missing from a witness's original police statement but appears only at trial cannot be relied upon to convict.

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

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