VidhiSangh

Supreme Court of India · 30/01/2025

LALITA versus VISHWANATH & ORS.

[2025] 1 S.C.R. 1643 · 2025 INSC 173

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Summary

The Supreme Court upheld the acquittal of a husband and in-laws charged with abetting a married woman's suicide, holding that mere harassment or cruelty does not establish abetment and that Section 113A of the Evidence Act cannot be invoked without cogent evidence of cruelty; it also held that where the first informant dies of causes unconnected with the case, the contents of the FIR cannot be proved through the Investigating Officer.

Issues

  1. Whether the High Court erred in acquitting the accused of offences under Sections 306 and 498A read with Section 34 IPC.
  2. Whether the presumption under Section 113A of the Evidence Act established abetment of suicide.
  3. Whether, when the first informant has died before testifying from causes unconnected with the offence, the contents of the FIR can be proved through the Investigating Officer and read in evidence.

Provisions considered

Held

Result

Appeal by the deceased's mother dismissed; High Court's acquittal of all four accused upheld.

Judgment PDF: Supreme Court of India, [2025] 1 S.C.R. 1643.