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Calcutta High Court Acquits Man in 1987 Dowry Death Case, Sets Aside Conviction Under IPC Sections 498A and 306

Vivek G.

Purna Chandra Raul & Anr. vs State of West Bengal, Calcutta High Court acquits man in 1987 dowry death case, sets aside conviction under IPC Sections 498A and 306 citing weak evidence and trial lapses.

Calcutta High Court Acquits Man in 1987 Dowry Death Case, Sets Aside Conviction Under IPC Sections 498A and 306
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The Calcutta High Court has overturned the conviction of a man who had been sentenced to seven years of rigorous imprisonment in connection with the alleged dowry-related suicide of his wife in 1987. The Court held that the prosecution failed to present reliable and consistent evidence to establish cruelty or abetment of suicide beyond reasonable doubt.

Justice Prasenjit Biswas delivered the judgment on March 5, 2026, allowing the criminal appeal filed by the accused against the conviction passed by the Additional Sessions Judge in Midnapore more than three decades ago.

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Background of the Case

The case began after a complaint was filed by the brother of the deceased woman, who alleged that his sister had been subjected to harassment and torture by her husband and mother-in-law for additional dowry after her marriage.

According to the complaint, cash, ornaments, and other articles were given during the marriage. However, it was alleged that the husband later demanded more money to start a business. The victim reportedly told her family members that she was facing continuous pressure and ill-treatment over these demands.

The prosecution claimed that the harassment eventually pushed the woman to commit suicide on July 31, 1987. After an investigation, the accused were charged under Sections 498A (cruelty by husband or relatives) and 306 (abetment of suicide) of the Indian Penal Code.

The trial court convicted the accused in 1990 and sentenced him to seven years of rigorous imprisonment along with a fine of ₹2,000.

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Arguments Before the High Court

The defence argued that the conviction was based on unreliable testimony and serious procedural lapses in the investigation.

Counsel for the appellant pointed out that most witnesses were close relatives of the deceased and their statements contained contradictions and improvements made during the trial. It was also argued that the investigating officer had stated that these witnesses did not mention allegations of torture or dowry demand in their earlier statements.

Another argument raised by the defence was the delay in filing the complaint. The incident occurred on July 31, 1987, but the complaint was lodged several days later, and the prosecution failed to provide a convincing explanation for this delay.

The State, however, contended that the consistent statements of family members and a neighbour clearly showed that the deceased had faced harassment and mental torture for dowry, which ultimately drove her to commit suicide.

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Court’s Observations

After reviewing the evidence, the High Court noted several serious weaknesses in the prosecution’s case.

The Court found that key witnesses, including the brother, parents, and sister-in-law of the deceased, admitted during cross-examination that they had never reported the alleged harassment to the police before the victim’s death. Their conduct, according to the Court, appeared inconsistent with what would normally be expected if such serious cruelty had actually occurred.

“The unexplained delay in lodging the complaint and the unnatural conduct of the witnesses cast serious doubt on the credibility of the prosecution version,” the Court observed.

The Court also noted contradictions between the statements given in court and those recorded during the investigation. According to the investigating officer, several witnesses had not mentioned allegations of torture or dowry demand when their statements were first recorded.

Another major lapse highlighted by the Court was the failure to produce the post-mortem report as an exhibit during the trial.

“The non-production of such a vital document creates a gap in the chain of evidence and raises doubt regarding the completeness of the prosecution case,” the bench said.

Court on Abetment of Suicide

The Court also examined the legal requirements for proving abetment of suicide under Section 306 of the IPC.

It emphasized that the prosecution must show clear instigation, intentional aid, or a direct act that pushed the victim to take her own life.

“Mere allegations of harassment or strained relations are insufficient unless there is clear evidence of a direct and proximate link between the accused’s conduct and the suicide,” the Court noted.

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In this case, the Court found no evidence showing that the accused had intentionally provoked or encouraged the victim to commit suicide.

Decision of the Court

Considering the lack of reliable evidence, contradictions in witness statements, and procedural lapses in the prosecution case, the High Court concluded that the charges were not proved beyond reasonable doubt.

The Court set aside the trial court’s judgment dated March 8, 1990, and allowed the criminal appeal.

“The conviction under Sections 498A and 306 of the Indian Penal Code is not sustainable in the eye of law,” the Court held while acquitting the appellant.

The Court directed that the appellant be discharged from his bail bond and set at liberty, subject to legal requirements regarding bail bonds for future proceedings.

Case Title: Purna Chandra Raul & Anr. vs State of West Bengal

Case No.: C.R.A. 114 of 1990

Decision Date: 05 March 2026