The Chhattisgarh High Court reaffirmed that, in prosecutions under Section 304-B/34 IPC (dowry death with common intention), conviction cannot be sustained if initial reports and evidence lack specific allegations about dowry demand or observable injuries. The Court upheld existing precedent requiring clear, consistent, and timely accusations directly connecting the accused to cruelty or dowry demand. This decision is a binding authority on lower courts in Chhattisgarh and is of strong persuasive value elsewhere, particularly for cases involving evidentiary insufficiency in dowry death prosecutions.
Summary
| Category | Data |
|---|---|
| Case Name | ACQA/82/2016 of State Of Chhattisgarh Vs Heeralal |
| CNR | CGHC010285322016 |
| Date of Registration | 02-08-2016 |
| Decision Date | 31-10-2025 |
| Disposal Nature | DISMISSED |
| Judgment Author | Hon’ble Shri Justice Sanjay S. Agrawal, Hon’ble Shri Justice Radhakishan Agrawal |
| Court | High Court of Chhattisgarh, Bilaspur |
| Bench | Division Bench: Hon’ble Shri Justice Sanjay S. Agrawal & Hon’ble Shri Justice Radhakishan Agrawal |
| Precedent Value | Binding on subordinate courts in Chhattisgarh; persuasive value in similar cases |
| Overrules / Affirms | Affirms trial court’s acquittal based on evidentiary gaps; upholds existing principles |
| Type of Law | Criminal Law (Dowry Death – Section 304-B IPC, Section 302 IPC, Section 34 IPC, Criminal Procedure) |
| Questions of Law | Whether absence of specific allegations regarding dowry demand or injuries in initial complaints and medical evidence bars conviction under Sections 304-B/34 IPC. |
| Ratio Decidendi | The Court held that, where the initial reports (merg intimation and written complaint) lodged by the deceased’s father lack specific mention of dowry demand or injuries, and medical evidence fails to establish homicidal cause of death, the ingredients of Section 304-B/34 IPC are not established. The testimonies of the victim’s family, if inconsistent with initial reports and uncorroborated by material evidence or medical findings, cannot alone justify conviction. The absence of clear linkage between the alleged harassment, dowry demand, and the death renders the prosecution’s case insufficient in law. Consequently, acquittal by the trial court was found proper. |
| Logic / Jurisprudence / Authorities Relied Upon by the Court | Consistent statements in complaint and evidence, requirement of corroboration by medical findings, necessity for definite allegations of dowry demand and causation for conviction under Section 304-B IPC. |
| Facts as Summarised by the Court | Deceased (Babita Yadav) died under suspicious circumstances less than a year after marriage. Merg intimation by father cited unconsciousness and non-specific injuries; subsequent written report added allegations of dowry harassment. Testimonies at trial referred to harassment for four wheeler, but initial reports and medical evidence were inconsistent or inconclusive. Postmortem could not determine cause of death; no clear evidence of pressure marks or injury leading to death. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts in Chhattisgarh |
| Persuasive For | High Courts of other States and Supreme Court, especially when evaluating evidentiary sufficiency in dowry death prosecutions |
| Follows | Affirms established principles regarding necessity of specific, corroborated allegations for conviction under Section 304-B/34 IPC |
What’s New / What Lawyers Should Note
- Reaffirms that timely and specific allegations regarding dowry demand or harassment must be present in initial complaints and supported by medical evidence for conviction under Section 304-B IPC.
- Inconsistencies between initial reports and subsequent oral testimony, uncorroborated by medical findings, will weigh against prosecution.
- Medical opinion unable to definitively establish cause of death casts doubt, precluding conviction when foundational facts are lacking.
- Useful citation for defence lawyers in cases relying on vague or inconsistent dowry allegations or ambiguous medical evidence.
Summary of Legal Reasoning
- The Court examined the sequence and content of initial reports—the merg intimation and written complaint by the father of the deceased—finding that neither specifically attributed cruelty or dowry demand (for a four wheeler) as a motive or proximate cause of death.
- Testimony at trial alleging dowry harassment was inconsistent with the aforementioned reports, raising doubts about the veracity and sufficiency of the evidence.
- Medical and inquest reports did not conclusively establish homicidal injury or linking injuries on the deceased’s neck or back to the alleged crime. The postmortem doctors expressly stated no pressure marks or fatal injury were found.
- Applying these facts, the Court held that the basic ingredients of Section 304-B/34 IPC—cruelty/harassment soon before death “in connection with demand for dowry”—were not proved.
- Consequently, it upheld the trial court’s acquittal of the accused, finding no legal error or perversity in judgment.
Arguments by the Parties
Petitioner (State of Chhattisgarh):
- Challenged trial court’s acquittal on the ground that prosecution evidence established harassment and dowry demand.
- Relied on testimonies of deceased’s father and mother to prove cruelty and motive.
Respondents:
- Highlighted absence of specific allegations regarding dowry demand or injuries in initial merg intimation and written report.
- Emphasised inconsistencies between oral evidence at trial and contemporaneous documentary/medical evidence.
- Pointed out failure of medical evidence to establish homicidal cause of death.
Factual Background
The case involved the death of Babita Yadav, whose marriage to accused Heeralal occurred on 24/04/2012. She died under suspicious circumstances on 07/02/2013, less than a year after her marriage. Initial police notification (merg intimation) alleged she became unconscious and died en route to hospital, without mention of dowry harassment. A subsequent written report by her father alleged maltreatment for dowry. During trial, the deceased’s parents testified about demands for a four wheeler and harassment, but medical reports did not find clear evidence of death by injury or pressure marks. The cause of death remained uncertain.
Statutory Analysis
- Section 304-B IPC (dowry death): Requirement that soon before her death, a woman was subjected to cruelty or harassment by her husband or relatives in connection with dowry demand.
- Section 34 IPC (common intention): Requires proof of shared intent among multiple accused.
- Analysis emphasised that conviction under Section 304-B/34 IPC necessitates clear, specific, and corroborated allegations, and that vague or post facto charges unsupported by medical evidence fail statutory tests.
- The Court considered but found the evidence insufficient to satisfy the statutory elements required for conviction.
Dissenting / Concurring Opinion Summary
No dissenting or separate concurring opinion is recorded in the judgment.
Alert Indicators
- ✔ Precedent Followed – Existing law regarding evidentiary requirements for conviction under Section 304-B/34 IPC reaffirmed.