Bombay High Court Acquits Husband in 1998 Cruelty and Abetment of Suicide Case

Court Finds Insufficient Evidence to Support Charges of Cruelty and Abetment Against Accused Husband

In a significant judgment, the Bombay High Court has acquitted Ramprakash @ Popat Govind Manohar of charges under Sections 498A and 306 of the Indian Penal Code (IPC), concluding a legal battle that began in 1998. The court found that the evidence presented did not sufficiently prove the allegations of cruelty or the abetment of suicide against the appellant, who was accused following the tragic death of his wife, Rekha.

Justice M. M. Sathaye delivered the judgment on November 4, 2025, overturning the conviction and three-year rigorous imprisonment sentence previously handed down by the Additional Sessions Judge, Pune. The case revolved around allegations that the appellant and his mother harassed Rekha, leading her to commit suicide by drowning in a river between November 13 and November 17, 1997. The court, however, found that the prosecution's case lacked substantive evidence to establish the necessary legal ingredients of cruelty under Section 498A IPC or abetment of suicide under Section 306 IPC.

The High Court noted that mere expressions of unhappiness or instances of the deceased weeping did not suffice to meet the threshold of cruelty required for a conviction. Furthermore, the court observed that the demand for a sewing machine and Rs. 1,000 as dowry was not conclusively proven. The judgment emphasized the absence of a direct or active act of instigation or intentional aid by the appellant that could have led to the deceased's suicide.

During the trial, the prosecution's case relied heavily on the testimony of the deceased's parents, who alleged that the appellant made persistent demands for money and a sewing machine. However, these claims were found to be vague and lacking in material specifics. Additionally, a key witness turned hostile, and the purported seizure of the sewing machine from the appellant's house was deemed unreliable.

The court also highlighted the appellant's actions on the day of the incident, noting that he had filed a missing person report, indicating no intent or instigation to cause harm. The judgment referenced several precedents, including the Supreme Court's observations on the necessity of a clear proximate link between the accused's actions and the suicide, which was found lacking in this case.

In conclusion, the court ordered the appellant's acquittal and directed him to execute a P.R. Bond of Rs. 15,000 under Section 481 of the Bharatiya Nagarik Suraksha Sanhita, 2023, ensuring his appearance if an appeal is filed. This judgment underscores the importance of concrete evidence in cases involving serious charges such as cruelty and abetment of suicide.

Bottom Line:

The evidence on record did not sufficiently establish the ingredients of cruelty under Section 498A IPC or abetment of suicide under Section 306 IPC - The court emphasized that mere statements of unhappiness or weeping by the deceased were insufficient to conclude cruelty or harassment beyond reasonable doubt.

Statutory provision(s): Indian Penal Code, 1860 Sections 498A, 306, 107; Bharatiya Nagarik Suraksha Sanhita, 2023 Section 481

Ramprakash @ Popat Govind Manohar v. State of Maharashtra, (Bombay) : Law Finder Doc Id # 2804967