The Supreme Court has set aside the conviction of a father-in-law under Section 498A of the Indian Penal Code (IPC), holding that the prosecution failed to establish charges of cruelty and dowry beyond reasonable doubt.
The bench of Justice Aravind Kumar and Justice N.V. Anjaria has observed that testimonies of the deceased’s family members contained material improvements and omissions. Crucially, allegations of dowry demand were absent in their initial statements to the police and appeared to have been introduced later during trial. The Court termed such improvements as casting serious doubt on their credibility.
The case arose from the death of a young woman who suffered burn injuries within nine months of her marriage in 2001. The prosecution alleged that she was subjected to cruelty and dowry harassment by her husband and in-laws, culminating in her being set on fire. However, the case was marked by two contradictory dying declarations—one accusing the in-laws of setting her ablaze, and another stating that she had set herself on fire due to distress.
The Trial Court had convicted the husband and his parents under Sections 302 and 498A IPC, sentencing them to life imprisonment for murder. However, the Madhya Pradesh High Court later acquitted them of the murder charge under Section 302 IPC while upholding the conviction under Section 498A IPC, reducing the sentence to the period already undergone.
Before the Supreme Court, the father-in-law challenged his conviction, arguing that there was no reliable evidence to prove cruelty or dowry demand and that the dying declaration implicating him was unreliable. Simultaneously, appeals were filed by the deceased’s brother and the State seeking restoration of the murder conviction.
The Supreme Court, after examining the evidence, noted that the case suffered from serious inconsistencies. It emphasized that the two dying declarations were materially contradictory—while the first alleged homicide, the second suggested suicide. The Court found the second declaration more credible, observing that the first appeared to have been influenced or “tutored,” especially as witnesses admitted that persons present at the hospital had prompted the victim while her statement was being recorded.
Another key factor was the lack of corroborative evidence. Independent witnesses, including neighbours, either turned hostile or stated that the deceased had cordial relations with her in-laws. Additionally, a letter allegedly written by the deceased expressing distress was held unreliable as it was not proven through forensic or handwriting analysis.
On the evidentiary value of dying declarations, the Court reiterated that while such statements can form the sole basis of conviction, they must be free from suspicion and consistent with surrounding circumstances. Where multiple dying declarations exist and are inconsistent, courts must exercise caution and assess their reliability in light of the overall evidence.
The Court underscored the principle that in criminal cases, if two views are possible, the one favouring the accused must be adopted. It also reiterated that circumstantial evidence must form a complete chain pointing only to the guilt of the accused, failing which conviction cannot be sustained.
The Bench cautioned against the tendency to implicate all family members in matrimonial disputes without specific evidence, noting that Section 498A IPC is intended to protect women but should not be misused to rope in relatives without clear roles attributable to them.
Concluding that the prosecution failed to prove cruelty or dowry demand against the father-in-law, the Supreme Court allowed his appeal and set aside his conviction under Section 498A IPC. The appeals filed by the State and the complainant seeking conviction under Section 302 IPC were dismissed.
Case Details
Case Title: Narendra Singh Versus The State of Madhya Pradesh
Citation: JURISHOUR-1041-SC-2026
Case No.: Criminal Appeal No. 302 Of 2014
Date: 30/04/2026
