In Brief
The appellants were convicted of subjecting the appellant's wife to cruelty under Section 498A and abetting her suicide under Section 306 of the IPC within eight months of marriage. The wife died by consuming pesticide. The Supreme Court upheld the conviction, holding that all three conditions under Section 113-A of the Evidence Act were satisfied: the suicide occurred within seven years of marriage, the accused caused cruelty to the wife regarding a monetary demand, and the defence led no rebuttal evidence. Evidence from family witnesses was credible and consistent. The Court rejected the argument that absence of independent witnesses undermined the prosecution case, noting that domestic violence typically leaves no external witnesses.", <parameter name="cited_cases">[{"raw_citation": "Maranadu and Anr. v. State by Inspector of Police, Tamil Nadu", "case_name": "Maranadu and Anr. v. State by Inspector of Police, Tamil Nadu", "paragraph": "23", "treatment": "relied", "treatment_by": "this_court"}, {"raw_citation": "Dalip Singh and Ors. v. The State of Punjab (AIR 1953 SC 364)", "case_name": "Dalip Singh and Ors. v. The State of Punjab", "cited_year": "1953", "paragraph": "23", "treatment": "relied", "treatment_by": "this_court"}, {"raw_citation": "Guli Chand and Ors. v. State of Rajasthan (1974 (3) SCC 698)", "case_name": "Guli Chand and Ors. v. State of Rajasthan", "cited_year": "1974", "paragraph": "23", "treatment": "followed", "treatment_by": "this_court"}, {"raw_citation": "Vadivelu Thevar v. State of Madras (AIR 1957 SC 614)", "case_name": "Vadivelu Thevar v. State of Madras", "cited_year": "1957", "paragraph": "23", "treatment": "referred", "treatment_by": "this_court"}, {"raw_citation": "Rameshwar v. State of Rajasthan (AIR 1952 SC 54)", "case_name": "Rameshwar v. State of Rajasthan", "cited_year": "1952", "paragraph": "23", "treatment": "referred", "treatment_by": "this_court"}, {"raw_citation": "State of Punjab v. Jagir Singh (AIR 1973 SC 2407)", "case_name": "State of Punjab v. Jagir Singh", "cited_year": "1973", "paragraph": "23", "treatment": "referred", "treatment_by": "this_court"}, {"raw_citation": "Lehna v. State of Haryana (2002 (3) SCC 76)", "case_name": "Lehna v. State of Haryana", "cited_year": "2002", "paragraph": "23", "treatment": "referred", "treatment_by": "this_court"}, {"raw_citation": "Gangadhar Behera and Ors. v. State of Orissa (2002 (8) SCC 381)", "case_name": "Gangadhar Behera and Ors. v. State of Orissa", "cited_year": "2002", "paragraph": "23", "treatment": "referred", "treatment_by": "this_court"}, {"raw_citation": "Ramesh Kumar v. State of Chhattisgarh", "case_name": "Ramesh Kumar v. State of Chhattisgarh", "paragraph": "31, 34", "treatment": "relied", "treatment_by": "this_court"}, {"raw_citation": "Ramesh Vithal Patil v. State of Karnataka & Ors.", "case_name": "Ramesh Vithal Patil v. State of Karnataka & Ors.", "paragraph": "39", "treatment": "relied", "treatment_by": "this_court"}, {"raw_citation": "Satish Shetty v. State of Karnataka", "case_name": "Satish Shetty v. State of Karnataka", "paragraph": "40", "treatment": "relied", "treatment_by": "this_court"}, {"raw_citation": "K. Prema S. Rao & Anr. v. Yadla Srinivasa Rao & Ors.", "case_name": "K. Prema S. Rao & Anr. v. Yadla Srinivasa Rao & Ors.", "paragraph": "40, 41", "treatment": "relied", "treatment_by": "this_court"}, {"raw_citation": "Gurjit Singh v. State of Punjab", "case_name": "Gurjit Singh v. State of Punjab", "paragraph": "42", "treatment": "distinguished", "treatment_by": "this_court", "treatment_quote": "In the said case, this Court found that though the prosecution was successful in proving the case under Section 498A of the IPC but the prosecution had failed to prove that the cruelty was of such a nature which left no choice to the deceased than to commit suicide. It was found that the prosecution has failed to place on record any evidence to establish beyond reasonable doubt that any act or omission of the accused instigated the deceased to commit suicide."}]
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