The case of satbir singh v state of haryana came before the Supreme Court of India for the last time on May 28, 2021. It featured a historic ruling in which the court defined the term “soon before” in relation to section 304b of the indian penal code 1860 (IPC), which was crucial in convicting the accused of his role in the victim’s dowry death. The court also examined the important idea of “audi alteram partem” and the need to grant the accused the opportunity to defend himself when necessary.
Even after centuries, the custom of dowries endures in many countries and plagues the lives of countless women. Every year, thousands of incidents involving dowry deaths and related crimes of physical and mental abuse are reported from nations such as India. Even though the custom has changed significantly over the past few decades, it is still practiced in secret even though it has been outlawed by Indian law for more than 60 years.
According to custom, a dowry is the amount of money or gifts given to the groom’s family by the bride’s family in the form of priceless movable or immovable property. The origins of the custom can be traced to the patriarchal system in which the bride’s family is coerced by the groom and his family into paying dowries that are extremely large. Failing to comply with these demands can have regrettable results, including brutality, domestic abuse, and dowry killings against women.
satbir singh v state of haryana Case Facts
- On July 1st, 1994, Satbir Singh, the appellant, wed the victim’s wife who has since passed away. The deceased’s father was notified on July 31, 1994, of his daughter’s critical condition, which led to her hospital admission. Nevertheless, the victim had already passed away from her burn injuries by the time her relatives arrived at the hospital.
- The deceased had previously been the target of harassment by the Appellants (her husband and his family) because she had brought less dowry than what they had asked, according to the victim’s family’s complaint. Conversely, the appellant said that the deceased had killed herself by putting herself on fire, and that this had only occurred a year into her marriage.
- Following a thorough examination of the facts and supporting documentation, the Trial Court found the Appellants guilty on December 11, 1997, of the offenses covered by Sections 304B and 306 of the IPC. As a result, they were sentenced to seven years and five years of rigorous imprisonment, respectively, for their respective offenses.
- The Appellants went to the Hon’ble High Court to contest the Trial Court’s ruling and overturn their conviction. Nevertheless, the High Court maintained the Trial Court’s decision and dismissed the appeal in an order dated November 6, 2008. The present case stems from their Special Leave Petition that they filed with the Hon’ble Supreme Court, contesting the decisions made by the lower courts.
satbir singh v state of haryana Issues
The court determined that there are really just two issues on this court’s docket.
- Was it right for the Trial Court and the High Court to find the accused guilty of the section 304b of the indian penal code charge?
- Was it right for the Trial Court and the High Court to find the accused guilty of the section 304b of the indian penal code charge?
Contentions by the Parties
Appellants:
- In his appearance on behalf of the appellants, the experienced attorney stated that the case had not completely ruled out the possibility of an accidental fire. Most importantly, the prosecution was unable to produce any proof that the accused had ever demanded a dowry.
- The prosecution was unable to demonstrate that the demand, if any, was made soon after the victim passed away.
Respondent:
- The respondent State’s experienced attorney argued that the appellants had failed to present any evidence that would have entitled the court to intervene in the concurrent rulings of the subordinate courts.
- The attorney particularly brought up the fact that the victim’s mysterious death happened within about a year after the marriage.
- The witnesses had repeatedly given particular examples of demands for dowries.
satbir singh v state of haryana Judgment
- The case of Major Singh v State of Punjab was cited by the court, wherein the necessary elements for a conviction under section 304 B were articulated. The primary prerequisites are that the woman must have died within seven years of marriage from burns, physical trauma, or other causes other than normal. She is forced to endure abuse since her spouse or her husband’s family has asked for a dowry.
- Women must be treated cruelly or harassed before they pass away. Strict interpretation of the term “soon before” will result in complete absurdity and defeat the purpose of the law.
- This court is unable to establish any straightjacket formulas. The court will decide whether the time between the victim’s death and the cruelty or harassment falls within the term that came before. For the purpose of determining it, it is essential to establish a direct and living connection between the victim’s death and the cruelty.
- The court cited the case of Bansi Lal v. State of Haryana to highlight the requirement that a death be presumed to be a dowry death if it can be demonstrated that the woman in question had been the victim of cruelty or harassment from the person in question shortly before she passed away, either in response to or independent of any dowry demand. Judges, the defense, and the prosecution have more responsibilities as a result of the mandatory presumption against the accused. As a result, the accused’s examination required by Section 313 of the CrPC cannot be viewed as a simple formality.
- As a result, it requires the Court to question the accused fairly, carefully, and cautiously. The accused must be presented with incriminating evidence by the court, and the latter must respond. The accused’s attorney is also obligated to carefully prepare his case from the beginning of the trial, taking into account the specifics of Section 304B of the IPC in conjunction with section 113b of the evidence act.
- The court also recognizes the significance of Section 232 CrPC, which requires it to proceed and schedule hearings especially for the presentation of defense evidence in the event that it determines that the accused is not qualified for an acquittal under its terms.
- Furthermore, section 304B does not distinguish between homicide, suicide, or accidents. It declares that any death that occurs outside of regular circumstances is a dowry death. It even covers situations in which homicides are presented as accidents.
- Concerning conviction under IPC 306, Issue 02 is raised. This part is only drawn in the event that the prosecution can provide proof of the suicide. The court cited Wazir Chand v. State of Haryana, wherein the court outlined the necessary elements for a conviction under section 306.
- In the Wazir Chand case, the court ruled that: A plain reading of this law (Section 306 IPC) indicates that it is necessary to prove that the other person committed suicide before a person may be found guilty of aiding and abetting their suicide.
- section 113a of the evidence act established the presumption of abetment of suicide against accused parties; nevertheless, in order to establish this presumption, the prosecution’s attorney must demonstrate that the deceased individual committed suicide.
It is concluded from the aforementioned conclusions, the evidence at hand, and the pertinent material that the appellants’ convictions under section 304b of the IPC were lawfully granted by the trial court and high court. Regarding the offence under section 306 of the IPC, however, section 306 was set aside since the prosecution was unable to produce sufficient proof that the deceased had committed suicide. As a result, the Supreme Court found them guilty merely of an IPC section 304b offense.
It is terrible that women must endure hardship and become victims of dowry death in a nation like India, where women have long been revered. A custom whose original purpose was to guarantee the girl would have enough property after marriage has disastrously evolved into meeting the unending and excessive demands of the groom’s family. Even though the law was created a long time ago, hundreds of women have lost their lives as a result of this harsh dowry system since there are insufficient enforcement measures in place.
Court cases continue to deal with issues like dowry demands, violence against women over dowries, and suicides by women who have committed suicide as a result of abuse from their husbands or his family. Despite numerous attempts to deter the offenses by enacting legislation imposing harsh penalties, the problem is made worse by the absence of an effective enforcement system.
With the goal of giving students the best coaching available for law entrance exams including the CLAT, AILET, and various other numerous state judiciary exams, Jyoti Judiciary Coaching, India’s Finest educational Platform, was established. Come enrol now with Jyoti Judiciary!
For any latest news, legal topics, judiciary exams notifications, patterns, etc watch Jyoti Judiciary’s YouTube channel for legal videos for any updates at
https://youtube.com/@jyotijudiciarycoaching4852?si=2cwubh9d2A9urwJf
