The Supreme Court has upheld the conviction of a husband for his wife’s death under suspicious circumstances, supporting the Allahabad High Court’s decision. The case involves a woman found dead with 100% burn injuries at her home in Azamgarh, just two years after marriage.
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NEW DELHI: The Supreme Court has upheld the conviction of a husband accused of causing the death of his wife under suspicious circumstances. The judgment, delivered by a bench comprising Justice C.T. Ravikumar and Justice Sanjay Karol, supports the earlier decision of the Allahabad High Court, which had overturned a trial court’s acquittal.
The case, which dates back to September 1, 1994, involves the tragic demise of a woman who was found dead due to 100% burn injuries at her matrimonial home in Azamgarh, Uttar Pradesh. Married to the accused in 1988, she moved in with her husband following a traditional ‘Gauna’ ceremony in 1992. The incident occurred just two years later, within the critical seven-year period after marriage—a timeframe under Indian law that is crucial in dowry-related death cases.
Initially, the woman’s death was treated as an accidental fire, and her body was cremated the same day. However, lingering doubts led to the registration of a First Information Report (FIR) nearly two months later, on October 20, 1994, at the Jeeanpur Police Station in Azamgarh. The case was registered as Crime No. 348 of 1994, and subsequent legal proceedings (Session Trial No. 484 of 1995) led to the husband’s acquittal by the trial court.
The crux of the case revolved around Sections 304B and 498A of the Indian Penal Code (IPC), which deal with dowry deaths and cruelty by a husband or his relatives, respectively. The prosecution contended that the deceased had been subjected to continuous cruelty and harassment over dowry demands, which ultimately led to her untimely death.
In defense, senior advocate Mr. Rajbir Bansal argued that the FIR had been lodged with considerable delay, casting doubt on the veracity of the allegations. He further contended that there was no substantive evidence to support claims of dowry demands or harassment prior to the woman’s death.
“The High Court has misjudged the evidence, especially the testimony of crucial witnesses.”
-the defense asserted.
On the other side, the State of Uttar Pradesh, represented by advocate Ms. Srishti Singh, argued that the High Court had thoroughly re-evaluated the evidence after the Supreme Court had remanded the case for reconsideration.
Ms. Singh emphasized that-
“Under Section 113B of the Indian Evidence Act, 1872, the burden of proof shifted to the husband to clarify the circumstances surrounding her death, particularly since it occurred within the matrimonial home.”
In its detailed judgment, the Supreme Court observed that the death had occurred within seven years of marriage and under highly suspicious circumstances, involving 100% burn injuries while the deceased was in her matrimonial home. The Court took note of the consistent testimony provided by the deceased woman’s family, which painted a grim picture of ongoing cruelty and harassment related to dowry.
The Supreme Court underscored the significance of Sections 113B and 106 of the Indian Evidence Act in cases like these. According to the Court, once the prosecution has established the foundational facts, such as the timing of the death in relation to the marriage and the nature of the death, “the burden shifted to the husband to disprove the allegations.” The Court found that the husband had failed to provide any plausible explanation for how the woman sustained such grievous burn injuries, particularly given that he was present in the same room but emerged unharmed.
Quoting from the judgment, the bench stated-
“Once the prosecution has met its burden and established the relevant facts, it was up to the appellants, under Section 113B of the Evidence Act, to demonstrate that the death was not a dowry-related incident.”
The Court further pointed out that the husband’s silence and failure to provide an explanation under Section 313 of the Criminal Procedure Code (CrPC) were particularly damning.
The Supreme Court also highlighted the importance of the presumption under Section 113B of the Indian Evidence Act, which places the onus on the husband in dowry death cases to provide a satisfactory explanation for the wife’s death.
The bench observed that –
“The husband’s inability to clarify the circumstances surrounding the tragic incident, particularly given the severe burn injuries sustained by the deceased, suggested his culpability.”
