Rajasthan High Court Reverses Acquittal in 2001 Dowry Death Case; Incident Happened Inside In-Law’s Home, They Knew About the Death by Burns.
The Rajasthan High Court has reversed the acquittal in the 2001 Dowry Death Case, stating that the incident occurred within the in-laws’ home. The Court was reviewing a Criminal Appeal filed by the State against the Trial Court’s acquittal. A Division Bench, including Justice Pushpendra Singh Bhati and Justice Madan Gopal Vyas, noted that the incident happened inside the accused’s house and that the victim’s death by burns is something only the accused would know about. The prosecution successfully proved the key elements of Section 304-B IPC, which shifted the burden of proof to the accused under Section 106 of the Indian Evidence Act, 1872. However, the accused did not provide any clear explanation regarding the circumstances of the incident.
Advocate C.S. Ojha represented the Appellant, while Advocate B.S. Rathore represented the Respondents. A written complaint was filed by a person stating that his younger sister, the deceased, had been married to the accused three years prior, and that dowry was given according to their social status. The deceased had informed her family about the dowry demands and ongoing harassment from her father-in-law and mother-in-law for the past 7-8 months, claiming her family had provided insufficient dowry. Based on this complaint, a case was registered under Sections 304-B, 498-A, and 201 of the Indian Penal Code (IPC). The accused were arrested but later released on bail. The Trial Court acquitted them, giving them the benefit of the doubt, prompting the State to appeal to the High Court.
The High Court, considering the details of the case, stated, “After reviewing the Naksha Mauka (Ex.P. 4), it is evident that burnt clothing, clay, and an empty plastic container were discovered at the scene. Additionally, the house had a strong smell of kerosene. This not only supports the prosecution’s case but also requires the accused to explain the presence of these items in their home under Section 106 of the Indian Evidence Act. Without any explanation from them, the case leans against them.”
The Court also observed that the prosecution met its initial burden and established its case by demonstrating the key elements of the offense. Meanwhile, the accused did not fulfill their responsibility as outlined in Section 106 of the Indian Evidence Act, 1872. As a result, the High Court granted the Appeal, annulled the contested Judgment, and reversed the acquittal.
Cause Title: State of Ramdin and Anr. (Neutral Citation: 2024:RJ-JD:43838-DB)
