In Brief
A woman committed suicide by hanging in 1990. Her father filed a complaint over three months later alleging cruelty for dowry under Section 498A IPC and cover-up under Section 201 IPC. The trial court convicted the appellant on both counts. The High Court acquitted him of the 498A offence but maintained the 201 conviction solely because he failed to inform police or arrange a post-mortem before the last rites. The Supreme Court held that conviction under Section 201 requires proof that an offence occurred, the accused knew of it, destroyed evidence, and intended to shield the offender. Non-disclosure of an unnatural death alone is insufficient without these elements. The appeal was allowed and the Section 201 conviction was set aside.
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