The Lucknow Bench of the Allahabad High Court has upheld the conviction of three family members in a dowry death case involving a young woman who suffered severe burn injuries and later died during treatment.
A Division Bench of Justice Rajesh Singh Chauhan and Justice Indrajeet Shukla dismissed the criminal appeal filed by the convicts and held that the victim’s dying declaration, recorded in hospital shortly after the incident, carried strong evidentiary value.
Background of the Case
According to the prosecution, Sujata was married to Sunil Kumar around one-and-a-half years before the incident. Her father alleged that after the marriage, her husband Sunil Kumar, mother-in-law Ramrati and father-in-law Babulal began demanding a motorcycle and a fan as additional dowry.
The family claimed that Sujata repeatedly informed them about harassment and physical abuse linked to the dowry demand. On May 13, 2012, the complainant received information that Sujata had sustained burn injuries and had been admitted to Civil Hospital, Lucknow.
During treatment, her statement was recorded by the then SDM, Malihabad. In that statement, she alleged that her husband and in-laws assaulted her, poured kerosene on her and set her on fire over dowry demands.
Sujata later died on June 4, 2012 due to septicemia caused by ante-mortem burn injuries. The post-mortem report noted nearly 90 percent burn injuries on her body.
Trial Court Conviction
The trial court had convicted all three accused under Sections 304-B and 498-A of the Indian Penal Code and Section 4 of the Dowry Prohibition Act.
Ramrati was awarded life imprisonment, while Sunil Kumar and Babulal were sentenced to 20 years’ rigorous imprisonment under Section 304-B IPC.
The accused challenged the conviction before the High Court, arguing that the deceased had set herself on fire and that the prosecution case was false.
Court’s Observations
The High Court examined the testimony of the victim’s parents, uncle, medical witnesses and the Executive Magistrate who recorded the dying declaration. The Bench observed that the declaration had been recorded when the victim was conscious and medically fit to speak.
The Court discussed the legal principles governing dying declarations in detail and noted that such statements can form the sole basis of conviction if they inspire confidence.
The Bench observed that, “There cannot be an absolute rule of law that the dying declaration cannot form the sole basis of conviction unless it is corroborated.”
The judges also referred to Supreme Court precedents dealing with dowry death and the interpretation of the phrase “soon before death” under Section 304-B IPC.
While the defence witnesses claimed that Sujata had set herself on fire voluntarily, the High Court found that the prosecution evidence, particularly the dying declaration, remained consistent and trustworthy.
Decision
After re-evaluating the evidence, the High Court concluded that the prosecution had successfully established the ingredients of dowry death and cruelty under law.
The Bench upheld the conviction and sentences awarded by the trial court against the husband, mother-in-law and father-in-law in the case.
Case Details
Case Title: Smt. Ram Rati and 2 Others vs State of U.P.
Case Number: Criminal Appeal No. 2275 of 2019
Judge: Justice Rajesh Singh Chauhan and Justice Indrajeet Shukla
Decision Date: May 22, 2026
