VidhiSangh

Supreme Court of India · 11/01/2022

STATE OF MADHYA PRADESH versus JOGENDRA & ANR.

[2022] 2 S.C.R. 295 · 2022 INSC 30

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Summary

The Court restored the husband’s and father-in-law’s convictions for dowry death and cruelty after the High Court wrongly excluded demands for house-construction money from dowry. The evidence showed persistent demands and harassment with a live connection to the woman’s death by burning within seven years of marriage. Her own requests to relatives, made under that pressure, did not make her complicit. Life imprisonment for dowry death was reduced to seven years’ rigorous imprisonment. Acquittals for abetment of suicide were left undisturbed for want of conclusive evidence of abetment.

Issues

  1. Whether demands for money to construct a house constituted dowry in the circumstances.
  2. Whether continuing harassment satisfied the proximity requirement for dowry death and what convictions and sentences should follow.

Provisions considered

Held

Result

State appeal partly allowed; both respondents’ Section 304B and 498A convictions and relevant trial sentences restored, with life imprisonment reduced to seven years’ rigorous imprisonment; Section 306 acquittals undisturbed; surrender within four weeks.

Judgment PDF: Supreme Court of India, [2022] 2 S.C.R. 295.