The Madhya Pradesh High Court has upheld the order of acquittal of the husband and in-laws in a case of dowry death after noting that the evidence of the parents and sister of the deceased woman did not inspire confidence. The High Court further held that the deceased being an educated lady could have lodged cruelty complaint against the accused persons.

The appeal before the High Court was filed by the complainant against the judgment of the Trial Court acquitting the respondents of charges under Sections 498-A and 304-B of the IPC.

The Division Bench of Justice Vivek Agarwal and Justice Rajendra Kumar Vani stated, “Had there being any cruelty meted out with the deceased, deceased being a staff nurse and educated lady of young age, could have lodge a complaint against accused persons. More so, an immediate action on behalf of parents of the deceased in this regard would have been taken in normal course.”

Amicus Curiae Shreesh Agarwal represented the Appellant while Government Advocate Arvind Singh represented the Respondents.

Factual Background

The case dates back to the year 2019, when a woman committed suicide by hanging herself in suspicious circumstances. After the inquiry, an FIR was registered against the respondents on the allegation that they used to demand a car, gold chain and money as dowry from the deceased due to which she committed suicide. After completion of investigation, a charge-sheet was filed before the Court of Sessions under Sections 498A, 304 B, 34 of IPC against the respondents. The accused/respondents abjured their guilt and pleaded complete innocence and they claimed to be tried. The Trial Court acquitted the respondents from the charge under Section 498A and 304B of IPC on the ground that the prosecution had failed to prove its case beyond reasonable doubt. Against the impugned judgment of acquittal, the appeal came to be filed by the appellant/ complainant.

Reasoning

On a perusal of the statements of these witnesses, the Bench found that they exaggerated the story. Material contradictions and variations were also revealed from their statements vis-à-vis their police statements.

The Bench took note of the fact that independent witness Mamta did not support the story of the prosecution; she supported the defence of the accused persons that the deceased was happily living with the in-laws. The Bench further noticed that the deceased was suffering from back pain and had complaints of migraine, coupled with the fact that the room where the deceased had committed suicide by hanging herself was a small room full of furniture. It was further noticed that the material, which revealed a possibility that the injuries which were found by the doctor might have been caused by hitting with said material or by falling due to the breaking of the blade of the fan.

The Bench thus held that the evidence of the parents and sister of the deceased did not inspire confidence inasmuch as cogent and reliable evidence. As per the Bench, no error was committed by the trial Court in acquitting the accused persons.

Thus, affirming the findings of acquittal of the accused respondents by the Trial Court, the Bench dismissed the appeal.

Cause Title: Dinesh Kumar Dubey v. Rachit Mishra (Neutral Citation: 2026:MPHC-JBP:12540)

Click here to read/download Order


Madhya Pradesh HCJustice Vivek AgarwalJustice Rajendra Kumar Vani

Tulip Kanth

Assistant Editor

Tulip Kanth is an Assistant Editor at Verdictum having over 5 years of experience in the field of legal journalism and editing. She extensively covers judgments of the Supreme Court, High Courts as well as Tribunals. She has previously worked with a legal publishing website where she oversaw the work of other editors and has also created updates on notifications of different Government Ministries. She holds an English Honours Degree from SGTB Khalsa College, Delhi University and has completed her LLB course with specialisation in Corporate Law from Amity University.