VidhiSangh

Supreme Court of India · 17/12/2021

PARVATI DEVI versus THE STATE OF BIHAR NOW STATE OF JHARKHAND & ORS.

[2021] 9 S.C.R. 711 · 2021 INSC 911

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Summary

The Court affirmed the husband’s dowry-death conviction and sentence but acquitted the mother-in-law, against whom only omnibus allegations were proved. The wife disappeared from her matrimonial home within months of marriage soon after dowry demands, and her body was identified from its partly intact face and clothes. The evidence established an abnormal death and the foundational conditions for the rebuttable statutory presumption against the husband, whose explanations were rejected. Those conclusions could not substitute for specific evidence against the mother-in-law. The husband was directed to surrender within four weeks; the mother-in-law was ordered released unless required in another case.

Issues

  1. Whether the circumstantial evidence established the dowry-death ingredients and presumption against the husband.
  2. Whether omnibus allegations sufficed to sustain the mother-in-law’s convictions.

Provisions considered

Held

Result

Husband’s appeal dismissed with surrender within four weeks; mother-in-law’s appeal allowed and convictions set aside, with release unless required in another case.

Judgment PDF: Supreme Court of India, [2021] 9 S.C.R. 711.