Court Imposes Rs. 25,000 Cost on State for Filing Irresponsible Appeal in Dowry Death Case Against Manohar and Others
In a significant ruling, the Madhya Pradesh High Court at Jabalpur has upheld the acquittal of Manohar and others in a high-profile dowry death case, originally adjudicated by the First Additional Sessions Judge, Asta District Sehore. The Division Bench, comprising Justices Vivek Agarwal and B. P. Sharma, dismissed the State's appeal, criticizing it as a misuse of judicial resources and an act of irresponsibility.
The case revolved around the tragic death of Anita, who was married to Manohar since February 2013. Anita died on December 25, 2018, due to the consumption of aluminum phosphide, as per the viscera report. The State had challenged the trial court's decision to acquit the accused of charges under Sections 304B and 498-A of the Indian Penal Code, and Sections 3 and 4 of the Dowry Prohibition Act, 1961. However, the High Court found the prosecution's case lacking in substantive evidence.
The judgment noted significant delays and contradictions in the statements of prosecution witnesses, including Anita's family members, who failed to establish any demand for dowry or harassment related to dowry. The court remarked that the cause of Anita's death appeared unrelated to dowry demands, and the evidence suggested alternative motives, such as personal conflicts and allegations of extramarital affairs.
Justice Vivek Agarwal, delivering the court's opinion, emphasized the absence of credible evidence to support the prosecution's claims. The court observed that the testimonies provided did not inspire confidence due to their inconsistent nature and delayed reporting. The ruling also highlighted that no dowry demands were reported to the police or local panchayat during Anita's lifetime, and such claims only surfaced posthumously.
In a stern reprimand, the court labeled the State's appeal as frivolous, filed under external pressures rather than a genuine pursuit of justice. The Bench imposed a cost of Rs. 25,000 on the State, directing that the amount be deposited with the Indian Red Cross Society, Jabalpur, within thirty days. The court also recommended recovering the cost from those responsible for the decision to file the appeal.
The judgment underscores the judiciary's intolerance towards misuse of judicial time and resources and serves as a reminder of the importance of thorough investigation and evidence-based prosecution in criminal cases.
Bottom Line:
Dowry Death - Acquittal upheld due to lack of evidence proving ingredients of Section 304B IPC and Dowry Prohibition Act - Delay in police statements and contradictions in witness testimonies weakened the prosecution's case - Filing of the appeal by the State deemed irresponsible, resulting in imposition of costs.
Statutory provision(s): Indian Penal Code, 1860 Section 304B, Dowry Prohibition Act, 1961 Sections 3 and 4, Criminal Procedure Code
State of Madhya Pradesh v. Manohar, (Madhya Pradesh)(Jabalpur)(DB) : Law Finder Doc Id # 2838639
