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Supreme Court of India 2020-12-02

SANDEEP KUMAR AND OTHERS vs STATE OF UTTARAKHAND AND ANOTHER

Bench: 3 — Rohinton Fali Nariman, K.M. Joseph, Aniruddha Bose

In Brief

Three appellants charged with dowry death under Section 304B IPC were acquitted by the Trial Court but convicted by the High Court. The Supreme Court reversed the conviction and restored the acquittal, holding the High Court erred in interfering with the Trial Court's verdict. The prosecution could not establish that death was unnatural or caused by poisoning—the FSL report ruled out poison, no poison was recovered from the house, and the victim's medical history (tuberculosis, eosinophilia, severe malnutrition) provided an innocent explanation. Prosecution testimony about dowry demands was riddled with contradictions. The Court emphasized that an appellate court can only overturn an acquittal upon 'very substantial and compelling reasons', not merely because two views of evidence are possible.

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Criminal Procedure Dowry Deaths Evidence Poisoning Cases Circumstantial Evidence Appellate Jurisdiction Section 304B IPC Section 113B Evidence Act

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