The Allahabad High Court has observed that life imprisonment in dowry death cases under Section 304B of the IPC should not be treated as a default punishment and must be reserved only for exceptional cases where circumstances justify the harshest sentence.
The ruling came while the court upheld the conviction of a husband and his parents in a 2012 dowry death case from Uttar Pradesh but reduced their jail terms to the period already undergone.
A division bench of Justice Rajesh Singh Chauhan and Justice Indrajeet Shukla said sentencing in dowry death cases must follow the principle of proportionality and individual culpability rather than mechanically imposing the maximum punishment available under law.
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Court upholds conviction based on dying declaration
According to Live Law, the case involved the death of a woman named Sujata, who suffered severe burn injuries within one and a half years of marriage. According to the prosecution, she was repeatedly harassed by her husband and in-laws for dowry, including demands for a motorcycle and a fan.
Before her death, Sujata gave a dying declaration before an executive magistrate in which she accused her husband, mother-in-law, and father-in-law of pouring kerosene on her and setting her on fire after repeated abuse linked to dowry demands.
The high court said the dying declaration was properly recorded and constituted substantive evidence capable of sustaining a conviction even without independent corroboration.
The bench also rejected the defence argument that the victim was unfit to give a statement because she had suffered extensive burns and was under medication.
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Why was the sentence reduced?
According to Live Law, although the court confirmed the conviction under Sections 498A and 304B of the IPC and provisions of the Dowry Prohibition Act, it found that the trial court had not provided sufficient reasons for imposing life imprisonment and lengthy jail terms.
The bench referred to the Supreme Court’s ruling in Hem Chand versus State of Haryana, which held that while courts can award punishment ranging from seven years to life imprisonment in dowry death cases, the maximum sentence should be imposed only in rare situations.
Observing that the mother-in-law had already spent over 15 years in jail and the husband and father-in-law had undergone more than nine and 10 years respectively, the court commuted their sentences to the period already served.
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Court explains the reverse burden in dowry deaths
According to Live Law, the judgment also discussed the evidentiary burden in dowry death cases, noting that such crimes usually occur within the confines of a household where direct evidence is difficult to obtain.
The court said the law deliberately places a reverse burden on family members living inside the house once the prosecution establishes that the woman faced dowry-related cruelty shortly before her death.
Rejecting the defence theory that the woman set herself ablaze after a dispute with a neighbour, the court held that the accused failed to rebut the statutory presumption of guilt under Section 113B of the Evidence Act.
