The Supreme Court has set aside the conviction of Sanjay Kumar in a matrimonial death case, holding that the High Court had erred in reversing his acquittal without showing that the Sessions Court’s view was perverse or impossible on the evidence available.
A Bench of Justice Ujjal Bhuyan and Justice Atul S. Chandurkar delivered the judgment on September 3, 2026, allowing the criminal appeal and acquitting Kumar of the charges under Sections 498-A and 306 of the Indian Penal Code.
Background of the Case
Sanjay Kumar had married Lata in January 2008. The prosecution alleged that she was subjected to harassment by her husband and his family members. In November 2009, she consumed a poisonous substance and later died while undergoing treatment.
The prosecution examined 15 witnesses. The Sessions Court, however, found that the allegations of dowry demand and cruelty had not been proved. It noted that much of the evidence was general or based on what witnesses had allegedly heard from others. The court also found no injuries on the victim and no earlier complaint regarding physical torture. It acquitted all the accused on June 10, 2010.
The High Court took a different view. It acquitted the other accused but reversed Kumar’s acquittal and convicted him under Sections 498-A and 306. He was sentenced to four years’ rigorous imprisonment with a ₹10,000 fine under Section 306 and two years’ rigorous imprisonment with a ₹5,000 fine under Section 498-A, with the sentences running concurrently.
Supreme Court’s Observation
The Supreme Court closely examined the evidence and found that the witnesses had largely spoken in general terms. The Court noted that they did not identify specific incidents of torture, harassment or dowry demand. Several witnesses had also admitted during cross-examination that they had not made certain allegations to the police earlier.
The Court further considered evidence showing that Kumar had sought medical assistance after his wife consumed the poisonous substance and immediately took her to hospital. The post-mortem report attributed the death to ingestion of poison, while no injury was found on her body.
The Bench stressed that an appellate court dealing with an acquittal must properly consider the trial court’s reasons and the presumption of innocence.
“the High Court was in error in reversing the acquittal of the appellant” without finding that the Sessions Court’s view was perverse or impossible on the evidence.
The Court also held that a conviction under Section 306 required proof of abetment, including the necessary intention to aid, instigate or abet suicide. Mere matrimonial discord, by itself, was not sufficient.
Decision
The Supreme Court concluded that the Sessions Court had correctly found that the prosecution failed to establish the charges beyond reasonable doubt. It held that the High Court had erred in reversing that acquittal.
The Court therefore quashed and set aside the High Court’s judgment dated August 17, 2016, acquitted Sanjay Kumar of the charges, and cancelled his bail bonds.
The criminal appeal was accordingly allowed.
Case Details
Case Title: Sanjay Kumar v. State of Himachal Pradesh
Case Number: Criminal Appeal No. 1108 of 2016
Judge: Justice Ujjal Bhuyan and Justice Atul S. Chandurkar
Decision Date: September 3, 2026
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