Allahabad High Court Upholds Acquittal in Dowry Death Case

Prosecution's Failure to Prove Cruelty or Harassment Results in Benefit of Doubt for Accused

In a significant judgment, the Allahabad High Court has upheld the acquittal of Ravi Kant, accused in a dowry death case, affirming the trial court's decision due to insufficient evidence proving cruelty or harassment related to dowry demands. The Division Bench comprising Justices Rajeev Misra and Dr. Ajay Kumar-II ruled on the criminal appeal filed by Ved Prakash Tyagi against the acquittal judgment dated September 17, 2025, by the Additional District & Sessions Judge, Court No. 10, Agra.

The case involved the alleged dowry death of Ankita, daughter of the appellant, who was married to Ravi Kant in April 2021. Ankita died on February 18, 2024, allegedly due to poisoning, leading to charges under Sections 498-A, 304-B of the Indian Penal Code (IPC), and Section 4 of the Dowry Prohibition Act. The prosecution claimed Ravi Kant had continuously harassed Ankita over unmet dowry demands, which led to her death.

However, the High Court found material contradictions in the testimonies of key witnesses, including the appellant and Amit Kumar Tyagi, cousin of the deceased. The evidence failed to establish specific acts of cruelty or harassment by Ravi Kant soon before Ankita’s death, a crucial element for invoking the presumption under Section 113-B of the Indian Evidence Act relating to dowry deaths. The court noted discrepancies in testimonies regarding dowry and harassment claims, undermining the prosecution’s case.

The trial court had previously acquitted Ravi Kant, observing no visible ante mortem injuries on Ankita’s body and the absence of credible evidence proving continuous harassment or cruelty associated with dowry demands. The High Court concurred with these findings, emphasizing that the prosecution did not meet the burden of proof required to establish the offences under the charged sections.

In the appeal, the High Court reiterated the principles guiding interference in acquittal cases, underscoring the requirement for patent perversity or misreading of evidence to warrant overturning a trial court’s acquittal. The bench found no such errors in the trial court’s judgment, asserting that the prosecution’s failure to prove harassment or cruelty meant the statutory presumption under Section 113-B was rebutted.

The judgment also highlighted procedural concerns, criticizing the trial court for writing the judgment partially in Hindi and partially in English, which could impede understanding for Hindi-speaking litigants. The High Court urged judicial officers to write judgments entirely in one language, either Hindi or English, to ensure clarity and accessibility.

The judgment is a reminder of the stringent evidentiary requirements in dowry death cases and the cautious approach appellate courts must adopt when considering appeals against acquittals. The decision underscores the importance of concrete evidence linking harassment or cruelty to dowry demands to sustain such charges.

Bottom Line:

Appeal against acquittal under Sections 498-A, 304-B IPC and Section 4 of Dowry Prohibition Act - High Court dismissed appeal, holding prosecution failed to prove cruelty or harassment connected with demand of dowry soon before death of deceased - Benefit of doubt granted to accused.

Statutory provision(s): Section 498-A IPC, Section 304-B IPC, Section 4 of Dowry Prohibition Act, Section 113-B Indian Evidence Act, Section 313 CrPC

Ved Prakash Tyagi v. State of U.P., (Allahabad)(DB) : Law Finder Doc Id # 2808314