SRI CHAND AND ANR. v. STATE OF PUNJAB INSC 692

Name of Case: Sri Chand & Anr. v. State of Punjab (19 September, 2014)

Citation: (2008) 13 SCC 216; AIR 2008 SC 2012

Facts of the Case:

Sri Chand and Darshan Kaur, an elderly couple, were the father-in-law and mother-in-law of Harpal Kaur, who married their son, Jaswant Lal. Harpal lived with her in-laws after the marriage. Within a short time, she was allegedly subjected to cruelty and harassment over dowry demands and tragedy struck when Harpal Kaur was found dead under suspicious circumstances in her marital home, with evidence suggesting that she was burned. Both the Trial Court and the High Court convicted Sri Chand and Darshan Kaur under sections 304B and 498A of the Indian Penal Code (IPC). They appealed to the Supreme Court, asserting their innocence.

Issue:

>Whether the appellants were guilty of subjecting the deceased to cruelty and harassment in connection to dowry demands under Section 498A of IPC.

>Whether Harpal Kaur's death could classify as a “dowry death” under Section 304B of IPC, and were the appellants responsible for it.

Holding:

The Supreme Court overturned the convictions. Sri Chand and Darshan Kaur were acquitted of all charges.

Rationale:

1)The Court found that the prosecution had not provided concrete and consistent evidence showing that Harpal Kaur was subjected to harassment and cruelty especially related to dowry demands.

2)To convict someone under IPC Section 304B, it must be proven that the deceased was harassed in connection to dowry demands shortly before their death. The Court noted that the evidence failed to establish this critical link.

3)Criminal cases require proof beyond a reasonable doubt and the evidence against Sri Chand and Darshan Kaur were circumstantial and insufficient to meet this standard.

4)The allegations against the accused appeared to be general and unsupported by specific, reliable evidence.