VidhiSangh

Supreme Court of India · 12/10/2022

MARIANO ANTO BRUNO & ANR. versus THE INSPECTOR OF POLICE

[2022] 14 S.C.R. 889 · 2022 INSC 1073

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Summary

A doctor and his mother were convicted under Sections 498A and 306 IPC after his wife, also a doctor, died by suicide nine years into the marriage, and the High Court affirmed. The prosecution rested on the deceased's mother, sister and brother, whose complaint came three weeks after the death. The Supreme Court acquitted both. No complaint of cruelty or dowry demand had been made during the marriage, the families' relations were admittedly cordial, and the brother called it a happy marriage. The psychiatrist the husband consulted the day before the death recorded a history of depressive episodes, an earlier suicide attempt and recent suicidal ideation. The courts below ignored that evidence. There was no proof of any positive act of instigation proximate to the suicide, or of cruelty under Section 498A.

Issues

  1. Whether the conviction under Section 306 IPC was sustainable without evidence of a positive act of instigation proximate to the suicide
  2. Whether the belated testimony of the deceased's family alone proved cruelty under Section 498A IPC
  3. Whether the courts below erred in ignoring the treating psychiatrist's evidence

Provisions considered

Held

Result

Appeal allowed; the judgments of the High Court and the trial court were set aside and both appellants acquitted under Sections 498A and 306 IPC.

Judgment PDF: Supreme Court of India, [2022] 14 S.C.R. 889.