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Virender Pal @ Vipin v. State of Haryana

Criminal Appeal · 2025 INSC 710Decided 15 May 2025
Crl.A. No.-000342-000342 - 2015
Justice Vikram Nath · Justice Sanjay Karol · Justice Sandeep Mehta

Background

The appellant's wife, Punita, died within about sixteen months of their marriage after falling from the terrace of her matrimonial home. Her family alleged that she had been continuously harassed for additional dowry, including a Rs. 5 lakh demand to fund the husband's job, and that on the morning of her death she had phoned her brother in distress saying she had been beaten the previous night and feared for her life. The trial court convicted the husband under Section 304-B IPC and the High Court upheld the conviction; he appealed to the Supreme Court, claiming his wife was depressed over a knee ailment and either fell accidentally or died by suicide unrelated to dowry.

Decision Breakdown

The Supreme Court found consistent testimony from the deceased's father and brothers about ongoing dowry harassment shortly before her death, including the phone call warning of danger to her life. It rejected the husband's shifting and contradictory defence theories (accidental fall versus suicide from knee pain) as an afterthought unsupported by evidence, noting medical witnesses confirmed her knee treatment was already working. Since the death was unnatural, occurred within seven years of marriage, and was preceded by proven dowry-related cruelty, the presumption under Section 113-B of the Evidence Act applied and the husband failed to rebut it. The conviction and ten-year sentence were upheld.

Lesson Learnt

Once a woman's unnatural death within seven years of marriage is linked to dowry-related cruelty suffered shortly before her death, the law presumes the husband/in-laws responsible unless they can convincingly disprove it, and offering inconsistent alternative explanations for the death only weakens the defence further.

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

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