LexSHAKUNTLA DEVI versus THE STATE OF UTTAR PRADESH
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[2025] 4 S.C.R. 1914 : 2025 INSC 581 Shakuntla Devi v. The State of Uttar Pradesh (Criminal Appeal No. 1131 of 2018) 25 April 2025 [Vikram Nath,* Sanjay Karol and Sandeep Mehta, JJ.] Issue for Consideration Issue arose as to the correctness of the order passed by the High Court wherein the appellant’s conviction u/ss.304B and 498A IPC and ss.3 and 4 of the Dowry Prohibition Act, 1961 was converted into that u/s.306 IPC. Headnotes† Penal Code, 1860 – ss.306, 304B, 498A – Dowry Prohibition Act, 1961 – ss.3, 4 – Abetment of suicide – Dowry death – Death of the victim in her matrimonial home – FIR by complainant- father of the victim alleging that the appellant-mother-in-law of the victim used to mentally and physically torture her for getting less dowry – Trial court convicted the appellant u/ss.304B and 498A IPC and ss.3 and 4 of the 1961 Act and sentenced accordingly – High Court acquitted the appellant of the said offences, however convicted her u/s.306 IPC on basis of the statement of the brother of the victim that the appellant behaved in a manner which led the victim to commit suicide by consuming poison – Interference with: Held: Not called for – Brother of the victim gave an account of events in a very natural manner that does not seem exaggerated or untruthful in any manner – Element of honesty and fairness in his statement throughout lends it much credibility – Family members of the deceased have been very precise in their allegations against the appellant – Complainant displayed honesty while making the allegations and has not unnecessarily implicated other family members of the husband of the deceased * Author [2025] 4 S.C.R. 1915 Shakuntla Devi v. The State of Uttar Pradesh by making omnibus allegations against all of them, which is usually the adopted tactic in cases of similar nature – Overall conduct of the prosecution unusually fair and honest and no reason to disbelieve the prosecution case – It is abundantly clear that the deceased was repeatedly tortured and abused by the accused on account of dowry demand – Abuses hurled at the deceased by the appellant on the day of the incident led her to committing suicide – Guilt of the appellant u/s.306 proved beyond reasonable doubt – High Court adequately considered the ground of old age of the appellant as a mitigating factor and awarded sentence of three years rigorous imprisonment which balances the interest of justice quite equitably – Impugned order upheld. [Paras 9-14] List of Acts Penal Code, 1860; Dowry Prohibition Act, 1961. List of Keywords Dowry death; Abetment of suicide; Interest of justice; Beyond reasonable doubt; Not unnecessarily implicating other family members; Mitigating factors; Old age; Omnibus allegations; Active act or omission leading deceased to commit suicide. Case Arising From CRIMINAL APPELLATE JURISDICTION: Criminal Appeal No. 1131 of 2018 From the Judgment and Order dated 22.03.2018 of the High Court of Judicature at Allahabad, Lucknow Bench in CRLA No.627 of 2003 Appearances for Parties Advs. for the Appellant: Ms. Vibha Datta Makhija, Sr. Adv., Nilakanta Nayak, Amit Yadav, Shishir Deshpande, Kaushal Narayan Mishra, Ms. Nehaol Sri L.V., Praveen Gaur. Advs. for the Respondent: Shaurya Sahay, Aditya Kumar, Ms. Ruchil Raj. 1916 [2025] 4 S.C.R. Supreme Court Reports Judgment / Order of the Supreme Court Judgment Vikram Nath, J. 1. The instant appeal has been preferred by the sole accused against the order dated 22.03.2018 passed by the High Court of Judicature at Allahabad in Criminal Appeal No. 627 of 2003 wherein the appellant’s conviction under Sections 304B and 498A of the Indian Penal Code, 18601 and Sections 3 and 4 of the Dowry Prohibition Act, 19612 was converted into that under Section 306 of the IPC with sentence of 3 years rigorous imprisonment. 2. Brief facts of the case are that the accused-appellant is the mother-in-law of the deceased, Smt. Kusum, who was aged about 22 years and was married to the son of the accused-appellant, one Rajendra Kumar, on 14.05.1997. Smt.Kusum died on 04.05.1998 at her matrimonial home. FIR dated 08.05.1998 was filed by the father of the deceased against the appellant under Sections 498A and 304B of the IPC along with Sections 3 and 4 of the DP Act. 3. It was alleged in the said FIR that the complainant had been informed numerous times by the deceased that her mother-in-law, i.e. the appellant herein, used to mentally
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