SC Restores Conviction of Father-in-Law in Dowry Death Case; False Electrocution Theory Exposed

In a recent matter before the SC concerning the death of Smt. Pushpa, who was married to Mahesh Singh, son of Janved Singh, the respondent the SC decided in favour of the State. Pushpa’s marriage soon turned turbulent due to continuous harassment and dowry demands by her husband and in-laws. On 31 December 1997, Janved Singh reported to Police Station Gormi that Pushpa had died from electrocution while ironing clothes. The police initially registered a Merg report under Section 174 CrPC but, upon investigation, converted it to a criminal case under Sections 302, 498A, 193, and 201 IPC after discrepancies were found at the scene.

A post-mortem examination by Dr. Devendra Khare revealed that Pushpa’s death was homicidal, caused by asphyxia due to strangulation, with burn marks found to be post-mortem. The Sessions Court (2000) convicted Mahesh Singh (husband) under Sections 304B and 498A IPC, and Janved Singh (father-in-law) under Sections 302, 498A, and 201 IPC for fabricating a false report and attempting to destroy evidence. However, the remaining accused, Pushpa’s mother-in-law, sister-in-law, and brother-in-law, were acquitted.

HC’s Decision: On appeal, the Madhya Pradesh High Court (2010) reversed Janved Singh’s conviction, acquitting him on the grounds that the marriage year was unproven, key witnesses’ statements were delayed, and there was no proof of his presence during the incident. The State of Madhya Pradesh appealed to the Supreme Court against his acquittal. The appeal against the husband (Mahesh Singh) had already been dismissed in 2011.

Main Issue: Whether the High Court erred in acquitting Janved Singh by ignoring credible medical and circumstantial evidence establishing his involvement in his daughter-in-law’s murder.

SC’s Decision: The SC allowed the State’s appeal, restoring the conviction and life sentence of Janved Singh. The Court found that the High Court had failed to properly appreciate material evidence and wrongly disbelieved consistent testimonies of the deceased’s parents and uncle regarding the dowry harassment and prior cruelty inflicted on Pushpa. Medical evidence conclusively ruled out accidental electrocution and confirmed strangulation as the cause of death.

The Bench held that the accused’s false report of electrocution was an additional incriminating circumstance under Section 106 of the Evidence Act. Since Pushpa’s death occurred inside the house occupied and controlled by Janved Singh, the burden was on him to explain the circumstances, which he failed to do. His explanation that he was at the field during the incident was unsupported by any independent witness.

The Court emphasized that each link in the chain of circumstantial evidence, unnatural death, the accused’s false story, the scene under his control, and proof of prior dowry-related cruelty, pointed solely toward Janved Singh’s guilt. Therefore, the High Court’s acquittal was set aside, the Sessions Court’s conviction restored, and the respondent was ordered to be taken into custody immediately to serve the remainder of his sentence.

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