The Supreme Court on Monday quashed a dowry death case against a man whose wife died by suicide in Toronto, Canada. It held that nothing on record connected the allegations against him to her death. A Bench of Justice B.V. Nagarathna and Justice Manmohan set aside the Bombay High Court’s refusal to quash FIR No. 212/2023 against Piyush, son of Deepak Narlawar.
Background
Piyush married the complainant’s daughter on January 3, 2021. The couple first lived in Chandrapur with his family and moved to Toronto on February 28, 2022. On June 11, 2023, she died after jumping from the 22nd floor of their apartment building. A handwritten note found in the flat spoke of her struggle to find a job and her feeling of failure.
Her father filed an FIR on June 30, 2023 at Satara Police Station, Aurangabad. He alleged repeated dowry demands, including 15 tolas of gold before the wedding, a gold ring and bracelet at Diwali, and three tolas of gold in September 2022. He also alleged verbal and physical abuse. The case was registered under Sections 304B (dowry death), 323, 498A, 504 read with 34 of the IPC and Sections 3 and 4 of the Dowry Prohibition Act.
Canadian authorities had meanwhile closed their inquiry. The coroner’s statement and the Toronto Police report noted that the handwriting matched the deceased, there were no signs of struggle, and CCTV footage showed the husband was not at home at the time. The Bombay High Court quashed the case against his parents and sister but let it continue against him. A chargesheet followed, and non-bailable warrants were issued.
The Bench noted that from the wedding until her death there was no complaint of dowry demands. It said this left “considerable room for doubt” about the allegations.
On the suicide note, the Court observed:
“Had there been even an iota of mental or physical agony caused by the unlawful demands of dowry by the appellant and his family, the same would, in the natural course, have found mention in the suicide note. However, the reality is that there is no mention of the appellant or his family in the said suicide note.”
The Court said gold given to both the bride and groom at a wedding, and gifts at the first Diwali, were plausibly customary and could not be treated as dowry without proof of a demand. It said the Rs 1,00,000 transferred by the wife’s brother was one of many transactions in the couple’s accounts and could not be viewed in isolation.
On the allegation of name-calling, the Bench held:
“The allegation that the appellant used to call the deceased ‘stupid’ and ‘useless,’ even if accepted prima facie, cannot to any extent qualify as an offence of cruelty or criminal intimidation. At best, it reflects on the temperament of the husband, but it cannot be given a criminal colour so grave as to become the reason for the suicide of his wife.”
It also found the allegations of cruelty, hurt and intimidation vague and general, without specific incidents.
The Court acknowledged the pain of the family but held that the prosecution could not continue. It said:
“Therefore, any legal process emanating from the impugned FIR against the appellant is an unfortunate instance of a father, grieving the bereavement of his daughter, searching for some semblance of reason as to why the deceased took such a drastic step to commit suicide.”
Relying on the Bhajan Lal guidelines, the Bench allowed the appeal and set aside the High Court’s order dated January 8, 2025.
It quashed FIR No. 212/2023 and all proceedings arising from it.
