VidhiSangh

Supreme Court of India · 13/09/2023

BUDDHADEB SAHA & ORS. versus THE STATE OF WEST BENGAL

[2023] 15 S.C.R. 332 · 2023 INSC 1084

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Summary

The Supreme Court declined to disturb concurrent convictions for cruelty and dowry death merely because the post-mortem report did not conclusively identify the cause and the viscera report detected no poison. Other medical observations, the inquest and surrounding evidence supported an unnatural death by poisoning, while the sample reached the laboratory after about five months. A negative toxicology result is not conclusive against poisoning; the prosecution case must be assessed as a whole without inventing missing circumstantial links.

Issues

  1. Whether the inconclusive post-mortem and negative viscera findings defeated the concurrent dowry-death convictions.

Held

Result

Appeal dismissed; concurrent convictions and sentences left undisturbed. The order noted that appellant 3 had died during pendency. Pending applications disposed of.

Judgment PDF: Supreme Court of India, [2023] 15 S.C.R. 332.