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Supreme Court of India 2021-05-28 partly_allowed

Satbir Singh & Another vs State of Haryana

Bench: 2 — N.V. Ramana

In Brief

A woman married in 1994 died of severe burn injuries in 1995. The Supreme Court affirmed the lower courts' conviction of her husband and mother-in-law under Section 304-B IPC (dowry death), finding evidence that the deceased faced harassment and dowry demands before her death. Once the statutory ingredients were proved, the rebuttable presumption of causation under Section 113-B Evidence Act operated against the accused. The Court clarified that 'soon before' in the statute means a proximate and live link, not immediate proximity. However, the Court set aside the conviction under Section 306 IPC (abetment of suicide) because the prosecution failed to establish that the deceased actually committed suicide—mere assumption was insufficient. The judgment emphasized procedural safeguards in dowry death trials, including proper examination of the accused under Section 313 CrPC.

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Criminal Law Dowry Law Evidence Law Section 304-B IPC Presumptions Criminal Procedure Dowry Death Abetment of Suicide

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