Summary
The Supreme Court upheld the mother-in-law’s convictions for dowry death and cruelty while reducing life imprisonment to seven years’ rigorous imprisonment. Evidence established dowry-related harassment soon before the unnatural death within seven years of marriage. Assessing three dying declarations individually, the Court accepted the final declaration naming only the appellant and explaining her role, while finding the earlier accident accounts unreliable in their surrounding circumstances.
Issues
- Whether the evidence and the final dying declaration justified conviction despite two earlier accounts of accidental burning.
- Whether life imprisonment was warranted for the appellant’s dowry-death conviction.
Held
- The parents’ and relatives’ evidence established dowry harassment soon before death and the unnatural death occurred within seven years of marriage. These foundational facts attracted the dowry-death presumption, which the defence evidence did not reliably rebut. (¶¶ 14, 15, 18, 19)
- Multiple dying declarations must each be assessed on their own evidentiary merits; inconsistency with another does not automatically invalidate one. The early accounts were recorded while the deceased remained under her in-laws’ control, whereas the final account was medically certified and recorded by the Additional Tehsildar. (¶¶ 16, 17, 20, 21, 22, 23)
- The final declaration’s specific attribution to the mother-in-law, while describing the father-in-law extinguishing the fire and excluding other relatives from responsibility for the burning, supported its reliability. The High Court’s conviction was therefore justified. (¶¶ 21, 23)
- Life imprisonment under Section 304-B is the maximum rather than an automatic sentence. Considering the appellant’s age, family circumstances and the other circumstances, the Court substituted seven years’ rigorous imprisonment while preserving the fine and default sentence. (¶¶ 24, 25)
Result
Appeal partly allowed: convictions under Sections 304-B and 498-A IPC affirmed; life imprisonment reduced to seven years’ rigorous imprisonment inclusive of time already undergone. Fine and default sentence maintained. Parties to bear their own costs; pending application disposed of.