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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, Aniruddha Bose

In Brief

Two brothers-in-law were convicted of dowry death and abetment of suicide after a bride died of burn injuries one year into her marriage. She had allegedly disclosed dowry harassment and dowry demands to her brothers on multiple occasions, including a week before her death. The Supreme Court upheld the conviction under Section 304-B, IPC (dowry death), finding all essential ingredients proved: death by burns within seven years of marriage, prior cruelty for dowry demand, and a proximate link between the cruelty and death. However, the Court set aside the conviction under Section 306, IPC (abetment of suicide) as the prosecution had not proved that suicide actually occurred—mere assumption was insufficient. The bench clarified that 'soon before' in dowry death law is a relative term and does not mean immediately before, and emphasized judges' duty to examine accused fairly and seriously under Section 313, CrPC.

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Criminal Law Dowry Death Abetment of Suicide Evidence Presumption of Causality Criminal Procedure Substantive Criminal Law Statutory Interpretation

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