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Supreme Court of India 2023-10-19 partly_allowed

ANOTHER vs THE STATE OF KARNATAKA

Bench: 3 — S. Ravindra Bhat, Aravind Kumar

In Brief

A widow died from self-immolation after her marriage following alleged dowry harassment. She recorded a dying declaration before death despite severe burn injuries. The trial court convicted the in-laws for dowry death (Section 304B) and cruelty (Section 498A). The Supreme Court held the dying declaration admissible and genuine, but found insufficient causal link between dowry demands and suicide to sustain Section 304B conviction. However, the Court convicted them for abetment of suicide (Section 306)—though no specific charge was framed—based on the victim's statement about mental torture leading to her death. The Court emphasized that omission to frame a charge is not fatal if the accused understood the facts and had fair opportunity to defend themselves. Sentence reduced to time served plus fine.

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Dowry Law Criminal Procedure Evidence Law Dying Declaration Abetment of Suicide Section 306 IPC Section 304B IPC Section 498A IPC Dowry Prohibition Act Burden of Proof Judicial Discretion in Sentencing

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