Supreme Court Upholds Acquittal in 1998 Punjab Dowry Death Case
In a recent ruling, the Supreme Court upheld the acquittal of five individuals accused in a 1998 dowry death case from Punjab, citing unreliable and contradictory evidence. The bench, comprising Justices Aravind Kumar and Sandeep Mehta, dismissed the appeals filed by the State of Punjab against the 2014 Punjab and Haryana High Court judgment that had acquitted the accused.
Case Background
The case revolves around the tragic death of Kuldeep Kaur, who sustained 85% burn injuries on August 24, 1998, and succumbed to her injuries three days later. Her husband, Randhir Singh, and four in-laws were initially convicted of her murder by the trial court in 2002. However, the High Court acquitted them in 2014, a decision which the state challenged in the Supreme Court.
Key Legal Issues
1. The reliability of the dying declarations
2. The evaluation of evidence in appeals against acquittal
3. Contradictions in witness testimonies
Court's Decision
The Supreme Court dismissed the state's appeals, upholding the acquittal of the accused, and made several key observations:
On Dying Declarations
The court noted significant contradictions in the two dying declarations made by Kuldeep Kaur. Justice Mehta observed, "From an overall appreciation of the evidence available on record, the following indisputable conclusions can be culled out: There is no allegation whatsoever by the prosecution witnesses that the deceased was harassed or humiliated in the matrimonial home on account of any demand for dowry."
The court concluded that the first dying declaration recorded by a police officer (Exhibit PM) appeared to be a "post-investigation document manufactured with an aim to falsely implicate the accused."
On Evidence Appreciation
The bench emphasized the limited scope of interference in appeals against acquittal, stating, "If two views are possible, one favorable to the accused and the other favorable to the prosecution, the former would prevail. An interference with the judgment of acquittal is only permissible if the same suffers from patent illegality, perversity, or misreading of the evidence available on record."
On Witness Testimonies
The court found several contradictions in the statements of key prosecution witnesses, including the victim's sister and brother. Justice Mehta pointed out, "Apparently thus, the evidence of Guddi (PW-4) to the extent she claimed to have seen the victim in a burnt condition at her matrimonial home is false and cooked up."
Conclusion
The Supreme Court concluded that the High Court had rightly interfered with the trial court's conviction, stating, "The impugned order dated 17th July, 2014 rendered by the Division Bench of the High Court is based on an apropos appreciation of evidence available on record and hence, does not warrant any interference in these appeals against acquittal preferred by the State of Punjab."
Case Details
- Criminal Appeal Nos.: 660-661 of 2015
- Appellant: State of Punjab
- Respondents: Randhir Singh & Others
- Judges: Justice Aravind Kumar and Justice Sandeep Mehta
- Appellant's Counsel: Shri Vivek Jain, Deputy Advocate General
This verdict underscores the importance of reliable evidence in ensuring justice and highlights the judiciary's cautious approach in overturning acquittals based on contradictory testimonies and suspect documentation.
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