The Calcutta High Court has partly allowed appeals filed by the husband and the parents-in-law of a woman who died by suicide in 2014, holding that the prosecution successfully established the husband's role in subjecting the deceased to cruelty connected with dowry demands. At the same time, the Court found no convincing evidence against the parents-in-law and acquitted them. It also reduced the husband's sentence from life imprisonment to 10 years' rigorous imprisonment, observing that life imprisonment under Section 304B of the Indian Penal Code should be reserved for rare cases.
Background of the Case
The case arose from the death of Chayanika, who married Sajal Parui on 24 April 2010. According to the prosecution, after marriage she was repeatedly subjected to physical and mental harassment over demands for money. The prosecution alleged that she was pressured to obtain her share of the family's ancestral property by asking her brother to sell the land and hand over the proceeds.
On 23 June 2014, Chayanika and her minor daughter were found hanging inside the matrimonial home. Following a complaint lodged by her brother, police registered a case under Sections 498A, 302, 304B and 34 of the IPC. After investigation, charges were filed under Sections 498A and 304B of the IPC along with provisions of the Dowry Prohibition Act.
The trial court acquitted the accused of murder but convicted Sajal Parui and his parents under Sections 498A and 304B IPC. Sajal was sentenced to life imprisonment, while his parents received seven years' imprisonment. Both convictions were challenged before the High Court.
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The appellants argued that there was an unexplained two-day delay in lodging the FIR and that the prosecution had failed to establish any specific dowry demand. They also relied on a suicide note, which allegedly absolved the husband and his family of responsibility. A handwriting expert had confirmed that the note was written by the deceased.
The State, however, argued that dowry demands could take different forms and that continuous pressure on the deceased to secure money from her parental property amounted to a demand for dowry.
Court's Observations
The Division Bench upheld the trial court's finding that the woman's death was suicidal and that the child had died at the hands of her mother before she ended her own life.
Rejecting the challenge based on the delay in filing the FIR, the Court observed that the sudden death of a close family member could leave relatives shocked and unable to act immediately.
The Bench further found that the evidence showed continuous pressure by Sajal Parui on the deceased to obtain her share from the ancestral property. Although a woman has a legal right to claim her share in family property, the Court held that the circumstances demonstrated the demand was driven by the husband's pressure and therefore fell within the broader meaning of a dowry demand.
Referring to the suicide note, the Court noted that it indicated a passive threat that Sajal Parui might marry another woman if money was not arranged.
"The suicide note has clearly indicated that there was a passive threat from the side of the appellants that if the arrangement of money was not done... Sajal Parui may marry another girl for the second time,"
the Bench observed.
However, the Court reached a different conclusion regarding the parents-in-law. It found that while allegations had been made against them in the FIR, the evidence led during trial did not establish their active involvement in demanding money or committing cruelty.
"The observations... do not inspire confidence since we have found that there is no substantive piece of evidence against Harendra Chandra Parui and Rina Parui,"
the Bench said.
Decision
The High Court partly allowed Sajal Parui's appeal. While affirming his conviction under Sections 498A and 304B IPC, it reduced his sentence from life imprisonment to 10 years' rigorous imprisonment, relying on Supreme Court precedent that life imprisonment for dowry death should be imposed only in exceptional cases. The fine imposed by the trial court was left unchanged.
The Court also allowed the appeal filed by Harendra Chandra Parui and Rina Parui, holding that the prosecution had failed to produce cogent evidence against them. They were acquitted of all charges, and their bail bonds were ordered to be discharged.
Case Details:
Case Title: Sajal Parui v. The State of West Bengal
Case Number: CRA (DB) 183 of 2024 (with CRA 538 of 2017)
Judge: Justice Arijit Banerjee and Justice Apurba Sinha Ray
Decision Date: 2 July 2026
