SATVIR SINGH V. STATE OF HARYANA 

Case name	Satvir Singh v. State of Haryana
Citation	Criminal Appeal Nos.1735-1736 of 2010
Date of judgement	28th May,2021
Court	Hon’ble Supreme court of India
Appellant	Satvir Singh
Respondent	State of Haryana
Bench	Hon’ble CJI NV Ramana and hon’ble Justice Aniruddha Bose

INTRODUCTION:

The Hon’ble Supreme Court of India issued a significant ruling on May 29, 2021, which clarified the meaning of dowry death in Section 304B of the Indian Penal Code from 1860. In this article, you will learn about the facts and issues in the case as well as the analysis provided by the court and various rules for proving cases of dowry death.

FACTS OF THE CASE: 

The accused (Satvir) got married on July 1^st, 1994. The girl passes away one year after the marriage. The father of the girl was notified by phone on July 31, 1995, between 4:00 and 4:30 pm, that her daughter had been admitted to the hospital and was in critical condition. As soon as he learns of this, he heads to the hospital with his wife and son and discovers that her daughter has died from a fire. Next, he files a case against Satvir and his brother for allegedly aiding suicide in section 306 and dowry death in section 304b of the IPC. He took this action because, following their marriage, her daughter frequently confided in him and his son that, as a result of her smaller dowry, she was subjected to abuse and harassment in her new home.

The matter was taken to court, and on December 11, 1997, the trial court found the accused Satvir and his brother guilty under IPC sections 304b and 306, punishing them with seven years of rigorous incarceration under section 304b and five years of rigorous imprisonment under section 306.Following that, the defendants appealed the trial court’s decision to the Punjab and Haryana High Court in 1998.

After ten years, in 2008, the Punjab and Haryana High Court upheld the trial court’s decision and denied the accused parties’ appeal. Following that, Satvir and his brother petitioned the Supreme Court for special leave in accordance with Article 136 of the Indian Constitution. 

The Supreme Court issued a ruling on May 28, 2021, which mentions the following 12 guidelines regarding dowry deaths.

• First, the Supreme Court clarified what was meant by “soon before death.” It provided the trial court with guidelines stating that “soon before her death” does not imply that the court should remember that there should be a proper connection between dowry death and cruelty for dowry demanded by the husband or relatives just before the death of a woman. 
• Secondly, the guidelines stipulated that courts must consider the legislative intent to prevent the social evil of bride burning and dowry death whenever they interpret section 304b of the IPC.
• In order to proceed, the prosecution must first prove that section 304b is required. The rebuttable presumption of section 113b of the evidence act will also work against the accused once these requirements are met.The evidence act’s Section 113b, which addresses the presumption of dowry death, is covered in this guidelines section. In cases where it is unclear if someone is to blame for a woman’s dowry death and it is demonstrated that the woman was cruelly or harassed prior to her passing because of the dowry demand, the court will assume that the accused party is to blame, and the onus of proof will be on the accused. He must demonstrate that he was not the cause of these dowry deaths.
• The Supreme Court ruled that the “Pigeon Hole Approach” and section 304b of the IPC are not the same. Salmond proposed this idea, and this theory required adherence to certain stringent guidelines. However, the Supreme Court ruled that a more expansive interpretation of section 304b is necessary and that there is no need for such a strict application.
• The Supreme Court ruled that trial courts should exercise greater caution when using section 304b of the IPC and section 113b of the Evidence Act because these provisions are ambiguous. In these cases, the trial court should proceed with extreme caution. 
•  Section 313 of the CRPC, which gives the court the authority to question the accused, was discussed by the Supreme Court. The accused’s examination cannot be viewed as a mere procedural formality because it is grounded in the important natural justice principle of “Audi alteram partem,” which allows the accused to refute the allegations made against them. As such, the court has a duty to ask the accused questions in a fair and impartial manner.
• The Supreme Court ruled that the trial court should question the accused, taking into account the circumstances that suggest he is guilty, and get his response.
• The CPC’s Section 232 is discussed by the Supreme Court. According to this section, the judge will record an order of quiet if, after hearing both the prosecution and the defense, reviewing the prosecution’s evidence, and concluding that there is no evidence to support the accused’s current illegality, the judge determines that there is none. The Supreme Court therefore went on to say that judges ought to exercise this discretionary power with extreme caution and diligence.
• The defense’s evidence should be taken into consideration right away, according to the Supreme Court, if the trial court believes that the accused should not be found not guilty. This gives the accused person important legal protections.
• Trial courts must conduct their proceedings with an eye toward the right to a fair trial, among other things. The aforementioned provisions should not be abused as a means of stalling proceedings, the courts should be careful of this. There would be no point in justice if it was not administered promptly. 
• Supreme Court ruling: When imposing punishment and sentence, the presiding judge should adhere to the guidelines established by the Supreme Court.
• The threat of dowry death is growing daily, and occasionally it is even so severe that husband’s family members are charged even though they had no direct involvement in the offense. This is an instance where the court must proceed with caution. 

At the appellants’ hearing, the learned attorney argued that the prosecution had not proven that a dowry had even been demanded, and that the possibility of an unintentional fire is not completely eliminated in this case. In conclusion, the prosecution was unable to demonstrate that the demand, if any, was made close to the victim’s passing.Conversely, knowledgeable representation for the state in question argued that the appellants had failed to present any evidence that would have entitled this Court to intervene in support of the concurrent decisions made by the lower courts.   The deceased victim’s suspicious death happened within approximately a year of marriage, which was a point that the attorney specifically emphasized.   Furthermore, the dowry demands have been consistently mentioned by the witnesses in specific instances.   

ISSUES RAISED:

The court determined that there are essentially just two issues on this court’s docket.

Was it right for the Trial Court and the High Court to find the accused guilty of the Section 304B, IPC charge?

Was it right for the Trial Court and the High Court to find the accused guilty of the Section 306 IPC charge?

CONTENTIONS ON BEHALF OF APPELLANT : 

The following arguments were made by the Learned Counsel, who was representing the appellants:

1. It hasn’t been ruled out in this case that the fire was accidental.
2. The prosecution has not been able to provide evidence of a dowry demand.
3. Even in the event that a dowry demand was made, the prosecution has not demonstrated that the demand was made close to the deceased person’s death.

CONTENTIONS  ON BEHALF OF STATE -RESPONDENT:

The following statements were made by the knowledgeable attorney representing the respondent state:

1. The appellants had not presented any evidence that would have entitled the Supreme Court to intervene in the lower courts’ concurrent rulings. 
2. The victim’s death under suspicious circumstances within nearly a year of marriage was underlined. 
3. The witnesses have consistently described the precise instances in which dowry demands have been made. 

JUDGMENT: SATVIR SINGH V. STATE OF HARYANA

The appellants’ submission was denied by the Supreme Court, which concluded that

1. The first necessary component of the offense is demonstrated by the fact that the deceased person passed away on July 31, 1995, and the accused person married on July 1, 1994.

2. The death of the deceased, who suffered burn injuries to her body within seven years of her marriage, demonstrates the second necessary component of the offense.

3. A month after the marriage, the deceased returned to her paternal home due to harassment from her spouse and family due to her smaller dowry, as supported by additional evidence.
4. She reported the abuse and harassment she was receiving from her husband and in-laws even before a week had passed since her death. She was admitted to the hospital on July 31, 1995, and died a week later from burn injuries on her body.
5. The additional court ruled that each of these chains establishes a clear connection between the demand for dowry and death.
6.  The Supreme Court ruled that both lower courts had appropriately reviewed every piece of evidence.

7. The Supreme Court ruled that the prosecution had proven all necessary elements of dowry death, and the presumption under Section 113b would take effect.
8. Due to the doctor’s conclusion that there was kerosene oil on the body and hence no possibility of an accident, the appellants were unable to produce any evidence to support their claim that the death was the result of an accident

CONCLUSION:

According to the Supreme Court, the prosecution was able to demonstrate that the victim’s death was caused by burn injuries, which happened about a year after the marriage was consummated. In relation to the dowry demand, the deceased frequently revealed the physical abuse she had endured in order to receive the requested amount. Under section 304B, the court clarifies the true meaning of soon before and rules that it is up to the court’s discretion. Thus, the court upheld the accused’s conviction in accordance with IPC section 304B. In order to be found guilty under section 306 of the IPC, the prosecution must demonstrate that the deceased took their own life. The prosecution was unable to present enough proof to prove the deceased person committed suicide. Thus, the accused’s conviction pursuant to section 306 was overturned.

In light of this, the court found them guilty of an offence under section 304B of the IPC but not for section 306 of the IPC.

ANALYSIS:

The case of Major Singh v State of Punjab, in which the court determined the necessary elements for a conviction under the dowry death offence, and section 304B IPC, which addresses the offence of dowry death, were heard by the Supreme Court. An opening was highlighted by the phrase “soon before.” According to the court, applying a strict interpretation to this term will result in ridiculousness.The term “soon before” was interpreted liberally by the court, who took into account the significance of the section and concluded that a strict interpretation would have defeated the purpose for which it was established. In establishing a proximate link between cruelty and death, the court correctly held that “soon before” does not necessarily mean “immediately before” the death, but rather includes the time between harassment and death. 

Since the prosecution must establish that the accused is guilty of dowry death in order to overcome the presumption of causation, the court also issued guidelines to subordinate courts instructing them to record the accused’s statement with greater care and responsibility. The right to a speedy trial and the right to hear the other side should be balanced by the trial courts as well. Section 304 B refers to death “other than natural circumstances,” and the court correctly determined that this includes dowry deaths, which include murders and suicides that are disguised as accidents.

The appellant’s conviction under section 306 of the IPC was overturned by the Supreme Court. In reference to the conviction under section 306 IPC, the court cited the case of Wazir Chand v. State of Haryana and held that only the husband and/or his relative could be presumed to have assisted the deceased in taking their own life if the prosecution could demonstrate that the deceased had committed suicide. In rendering its decision, the Supreme Court carefully considered all relevant legal precedents and case law before rendering its verdict. 

This article is written by TAMANA SALARIA student at The Law School , University of Jammu; intern at legal vidhiya 

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