The Supreme Court upheld the conviction under Section 304-B IPC (dowry death), affirming that the prosecution proved demand of dowry, cruelty, and unnatural death within seven years of marriage. The Court emphasized the presumption under Section 113-B of the Evidence Act, shifting the burden to the accused, who failed to rebut it. It clarified that contradictory defenses (accidental fall vs. suicide) weaken the accused’s case, and consistent witness testimonies established dowry harassment. The judgment reinforced strict scrutiny of dowry-related deaths and dismissed the appeal, sustaining the 10-year rigorous imprisonment sentence.
Facts Of The Case:
The case involved the death of Punita (alias Gayatri), who married the accused-appellant Virender Pal on February 28, 2008. Within months of marriage, her family alleged she faced persistent harassment and dowry demands from her husband and in-laws. Despite giving Rs. 50,000 as additional dowry during a panchayat meeting where Rs. 5 lakh was demanded for the husband’s job, the harassment continued. On June 1, 2009, Punita called her brother alleging abuse before her body was found at her matrimonial home with fatal injuries. The prosecution charged the husband under Section 304-B IPC (dowry death), presenting 12 witnesses including family members who testified about dowry demands and harassment. The defense claimed Punita committed suicide due to depression from knee pain, examining 8 witnesses including doctors. The trial court convicted only the husband (excluding other family members) and sentenced him to 10 years rigorous imprisonment, which the High Court upheld. The Supreme Court dismissed the husband’s appeal, noting the prosecution proved all elements of dowry death: unnatural death within seven years of marriage, preceding cruelty related to dowry demands, and the accused’s failure to rebut the statutory presumption under Section 113-B of the Evidence Act. The judgment highlighted the accused’s inconsistent defenses and credible witness accounts establishing dowry harassment.
Procedural History:
The case originated with an FIR No. 335/2009 registered at Chandni Bagh Police Station, Panipat, under Sections 304-B/34 IPC after Punita’s unnatural death in 2009. The Sessions Court, Panipat, convicted the appellant-husband under Section 304-B IPC in 2011, sentencing him to 10 years’ rigorous imprisonment, while acquitting other family members due to insufficient evidence. The appellant challenged this in the Punjab & Haryana High Court (Criminal Appeal No. S-2212-SB/2011), which upheld the conviction in its 2014 judgment. The appellant then approached the Supreme Court via Special Leave Petition (Criminal Appeal No. 342/2015). In its May 15, 2025 judgment, a three-judge bench comprising Justices Vikram Nath, Sanjay Karol, and Sandeep Mehta dismissed the appeal, affirming the lower courts’ rulings. The SC emphasized the prosecution’s success in proving dowry-linked harassment under Section 304-B IPC and the appellant’s failure to rebut the presumption of dowry death (Section 113-B, Evidence Act). The Court rejected the appellant’s contradictory defenses (suicide vs. accidental fall) and highlighted consistent witness testimonies about dowry demands. The judgment reinforced stringent scrutiny in dowry death cases and ordered the appellant to surrender to serve the remainder of his sentence.
READ ALSO : Supreme Court Says Depositors First, Banks Later in NSEL Scam Case: MPID Act Overrides SARFAESI
Court Observation:
The Supreme Court made several critical observations while upholding the conviction under Section 304-B IPC. The bench emphasized that the prosecution had successfully established all essential ingredients of dowry death: (1) unnatural death within seven years of marriage, (2) subjection to cruelty/harassment, and (3) a clear nexus between such harassment and dowry demands. The Court noted that the deceased’s telephonic distress call to her brother hours before her death, complaining of abuse by her husband, constituted crucial evidence of “soon before death” harassment required under Section 304-B. It rejected the appellant’s contradictory defenses of accidental fall versus suicide due to knee pain as afterthoughts, observing that such inconsistent pleas indicated a fabricated version. The judgment reinforced the statutory presumption under Section 113-B of the Evidence Act, stressing that once basic facts are proven, the burden shifts conclusively to the accused to disprove dowry connection – which the appellant failed to discharge. Significantly, the Court criticized the trial court’s procedural lapse in accepting the medical officer’s affidavit without proper examination of injuries, but held this as a curable irregularity since the defense had cross-examined the witness. The bench also distinguished the husband’s greater culpability from acquitted relatives, noting his active role in dowry demands and moral-legal duty to protect his wife. Ultimately, the observations underscored the judiciary’s strict approach in dowry death cases to protect married women from harassment and violence.
Final Decision & Judgement:
The Supreme Court, in its final judgment dated May 15, 2025, dismissed the criminal appeal and upheld the conviction of the appellant-husband under Section 304-B IPC for dowry death. The three-judge bench unanimously affirmed the 10-year rigorous imprisonment sentence imposed by the trial court and confirmed by the High Court, finding no merit in the appellant’s claims. The Court ruled that the prosecution had conclusively established all essential elements of the offense: the deceased died an unnatural death within seven years of marriage; she was subjected to cruelty and harassment by her husband; and such mistreatment was directly related to persistent dowry demands. The judgment emphasized that the appellant failed to rebut the statutory presumption of dowry death under Section 113-B of the Evidence Act, particularly noting his contradictory and implausible defenses about the cause of death. The Court ordered the appellant, who was on bail, to surrender within four weeks to serve the remainder of his sentence. In its concluding remarks, the bench reinforced the judiciary’s commitment to stringent enforcement of anti-dowry laws as a deterrent against harassment of married women, while maintaining that the burden squarely rests on the accused to disprove the presumption of guilt in such cases. The judgment stands as a significant precedent in the interpretation and application of Section 304-B IPC and Section 113-B of the Evidence Act in dowry death cases.
Case Details:
Case Title:Virender Pal @ Vipin vs. State of Haryana Citation: 2025 INSC 694 Case Number: Criminal Appeal No. 342 of 2015 Date of Judgment: May 15, 2025 Bench: Justice Vikram Nath & Justice Sanjay Karol & Justice Sandeep Mehta
Download The Judgement Here