DATE: 11/02/2026
COURT: High Court of Madhya Pradesh
BENCH: Justice Vivek Agarwal and Justice
Rajendra Kumar Vani
FACTS:
The present appeal was filed by the
complainant challenging the judgment dated 25.05.2024 passed by the Tenth
Additional Sessions Judge, Jabalpur in Sessions Trial No.172/2020, whereby the
respondents were acquitted of charges under Sections 498-A and 304-B IPC. The
prosecution case was that Amrita Mishra, wife of accused Rachit Mishra, died by
suicide on 31.10.2019 by hanging. After a marg inquiry, an FIR was registered
alleging that the accused persons, husband and in-laws had subjected the
deceased to cruelty and harassment for dowry, specifically demanding a car,
gold chain, and money, which allegedly drove her to commit suicide.
During trial, the prosecution examined nine
witnesses, including the parents and sister of the deceased, who supported
allegations of dowry demand and cruelty. The defence examined three witnesses,
including neighbours and the accused himself, who deposed that the deceased was
living a normal and happy marital life, frequently travelled with her husband,
and was suffering from medical issues such as migraine and spinal pain. The
medical evidence confirmed death due to ante-mortem hanging, with some
contusions that could be caused by accidental contact or fall. The trial court,
upon appreciation of evidence, acquitted the accused, leading to the present
appeal against acquittal.
ISSUES:
The principal issues before the High Court
were whether the prosecution had proved beyond reasonable doubt that the
deceased was subjected to cruelty and dowry-related harassment “soon before her
death” so as to attract Sections 498-A and 304-B IPC, and whether the trial
court’s judgment of acquittal suffered from perversity, illegality, or
misappreciation of evidence warranting appellate interference.
JUDGEMENT WITH REASONING:
The High Court dismissed the appeal and
affirmed the acquittal of the accused persons. It held that the prosecution
failed to establish the essential ingredients of the offences under Sections
498-A and 304-B IPC beyond reasonable doubt and found no perversity or
illegality in the trial court’s appreciation of evidence. Consequently, the
findings of acquittal were upheld.
The Court closely scrutinised the
testimonies of the prosecution witnesses, particularly the parents and sister
of the deceased, and found material contradictions, exaggerations, and
omissions when compared with their police statements. It noted that no prior
complaint or FIR regarding dowry demand or cruelty was ever lodged during the
four-year span of marriage. The witnesses were unable to specify dates, amounts,
or particulars of the alleged dowry demands or acts of cruelty. Independent
witness Mamta Rajak did not support the prosecution case and instead stated
that the deceased appeared to be living happily with her in-laws. The Court
also emphasised the absence of corroborative documentary evidence, such as bank
records, despite allegations of forcible withdrawal and transfer of money.
Further, the medical and circumstantial
evidence weakened the prosecution case. Though certain ante-mortem injuries
were noted, the medical expert conceded that such injuries could occur due to
accidental contact in a small, furniture-filled room or due to a fall if the
ceiling fan blade broke. Another prosecution witness who prepared the panchnama
found no visible external injuries. The defence evidence consistently suggested
that the deceased suffered from chronic migraine and spinal pain and was under
mental stress due to pressure from her parental family for money. In light of
two plausible views emerging from the evidence, the Court applied settled
principles governing appeals against acquittal and held that the view
favourable to the accused must prevail. Since the trial court’s conclusions
were legally plausible and based on proper appreciation of evidence, no
interference was justified.
ANALYSIS:
The judgment reflects a cautious and
evidence-centric approach adopted by the High Court while dealing with an
appeal against acquittal in dowry death cases. Although allegations under
Sections 498-A and 304-B IPC are serious and invoke statutory presumptions, the
Court reaffirmed that such presumptions arise only after the prosecution
establishes foundational facts, particularly cruelty or harassment for dowry
“soon before death.” In the present case, the prosecution evidence largely
rested on testimonies of close relatives of the deceased, which were found to
be inconsistent, vague, and uncorroborated by independent or documentary
evidence. The absence of any prior complaint, FIR, or contemporaneous grievance
during the four years of marriage significantly undermined the prosecution’s
narrative, especially when allegations of persistent dowry demand and cruelty
were made.
Equally significant is the Court’s
treatment of medical and circumstantial evidence. While the presence of ante-mortem
injuries could potentially raise suspicion, the Court correctly evaluated
expert testimony explaining plausible alternative causes consistent with
suicide in a confined space. The defence version, supported by independent
witnesses, medical history, and surrounding circumstances, presented a credible
alternative explanation for the deceased’s mental state, thereby creating
reasonable doubt. By applying settled principles governing appellate
interference with acquittals, the Court reinforced that suspicion, however
strong, cannot substitute proof beyond reasonable doubt, and that where two
views are possible, the one favouring the accused must prevail. The decision
thus underscores judicial restraint, evidentiary rigour, and adherence to the
presumption of innocence in criminal jurisprudence.
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