The Gujarat High Court on Wednesday refused to interfere with a 23-year-old acquittal in a dowry-death case, holding that a minor quarrel about visiting a temple could not be stretched into an act of “cruelty” capable of driving a young woman to suicide. The Division Bench of Justice Ilesh Vora and Justice R.T. Vachhani upheld the Nadiad Sessions Court’s 2002 order acquitting the husband and three in-laws of charges under Sections 498A, 304B, 306 and other allied offences of the IPC STATE OF GUJARAT.
Background
The case dates back to January 1999, when a 22-year-old woman from Thaledi village consumed Celphos poison after an argument at home. As per the mother’s complaint, she had been subjected to alleged harassment, dowry demands, and taunts by her husband and in-laws. The State argued that the death-occurring within seven years of marriage-should automatically trigger the legal presumption of abetment under Section 113A of the Evidence Act.
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Investigators recovered a poison container and later exhumed the body for post-mortem, which confirmed death due to Celphos poisoning but showed no external injuries suggesting recent assault. Some panch witnesses turned hostile; others could not connect the accused to active instigation.
The Sessions Court eventually acquitted all four accused in 2002, finding no credible evidence of cruelty “soon before death” STATE OF GUJARAT. The State challenged this acquittal under Section 378 CrPC.
Court’s Observations
The High Court spent considerable time analysing the testimonies, contradictions, and the scope of legal presumptions.
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The Bench noted that although the mother and sister spoke of dowry harassment, their statements were general and inconsistent, lacking dates, specific demands, or corroboration. As Justice Vachhani put it, “General wear and tear of matrimonial life cannot be branded as cruelty under Section 498A unless the conduct is wilful and of such intensity that it could push a woman to suicide.”
Most significantly, the court emphasised that the incident immediately preceding the suicide-a disagreement about allowing the woman to accompany her husband and mother-in-law to Nadiad’s Santram Mandir-was too trivial to qualify as cruelty. “A mere refusal to take the deceased to the temple cannot, by any stretch, be treated as wilful conduct driving her to suicide,” the Bench observed.
The court also found that the attempted dying declaration, which vaguely mentioned “family pressure,” was incomplete and lacked medical certification of voluntariness. The husband’s act of immediately rushing her to the hospital weighed heavily in his favour.
Regarding dowry-death allegations (Section 304B), the court bluntly noted that no evidence showed demand for dowry “soon before death”-a mandatory requirement. The first mention of dowry surfaced only during trial, not in the original FIR, weakening the prosecution’s stand.
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On the allegation that the family buried the body prematurely to destroy evidence, the Bench accepted their explanation of local religious customs requiring quick burial. The body was later exhumed by officials and thoroughly examined, ruling out any deliberate destruction of evidence.
Decision
Concluding that the prosecution failed to establish cruelty, abetment, or dowry demand beyond reasonable doubt, the High Court dismissed the State’s appeal. The Bench held that the trial court’s view was “a possible and reasonable view” and thus could not be overturned in an acquittal appeal.
The appeal was dismissed, and the acquittal of all four accused was confirmed.
Case Title: State of Gujarat vs. Rajeshbhai Pitamberbhai Parmar & Others
Case Number: Criminal Appeal No. 457 of 2002
Case Type: State Appeal Against Acquittal (Criminal)
Decision Date: 19 November 2025
