Calcutta High Court Acquits Accused in Dowry Harassment Case

Conviction under Section 498A IPC Overturned Due to Insufficient Evidence and Hostile Witnesses

In a significant judgment, the Calcutta High Court has overturned the conviction of Ranjit Saha and his family members under Section 498A of the Indian Penal Code (IPC), which pertains to cruelty by husband or relatives of husband. The case, which was initially decided by the Learned Additional Sessions Judge, 4th Court Nadia, involved allegations of dowry-related harassment and cruelty leading to the death of Saha's sister-in-law.

The judgment, delivered by Justice Chaitali Chatterjee Das, critically examined the evidence presented by the prosecution. The court found that the testimonies of witnesses, including those of the family members of the deceased, were fraught with inconsistencies and lacked concrete evidence to substantiate the claims of cruelty and harassment. Furthermore, many witnesses turned hostile, failing to provide corroborative evidence necessary for upholding the conviction.

The prosecution's case was significantly weakened by the absence of specific allegations and corroborative evidence. The court noted that the vague and omnibus allegations against the accused were insufficient to sustain a conviction under Section 498A IPC, which requires evidence of cruelty that drives a woman to commit suicide or cause grave injury. Additionally, the court found no evidence to support charges under Section 304-B IPC, which deals with dowry death.

The victim, who had sustained severe burn injuries, reportedly told neighbors that the incident was accidental, resulting from a gas cylinder mishap. The court observed that despite the tragic nature of the victim's death, the prosecution failed to prove beyond a reasonable doubt that the accused had subjected her to cruelty or harassment.

The judgment also highlighted the prosecution's failure to include the victim's husband as an accused or even as a witness, noting that he could have provided crucial insights into the family dynamics and the alleged harassment. The court emphasized the Supreme Court's stance that vague allegations cannot justify the trial of relatives of the husband.

In conclusion, the Calcutta High Court set aside the conviction and sentence imposed by the lower court, discharging the appellants from the bail bond and disposing of all connected applications. The court's decision underscores the importance of concrete evidence in upholding convictions in cases involving allegations of dowry harassment and cruelty.

Bottom Line:

Conviction under Section 498A IPC set aside due to lack of concrete evidence of cruelty or harassment against the appellants.

Statutory provision(s): 498A IPC, 304-B IPC, 306 IPC, Evidence Act, 1872

Ranjit Saha v. State of West Bengal, (Calcutta) : Law Finder Doc Id # 2812818