The Supreme Court has acquitted Brajesh Kumar @ Birjesh Kumar Singh in a 26-year-old dowry death case, holding that the prosecution failed to establish allegations of dowry harassment and cruelty beyond reasonable doubt. The Court also criticized the manner in which the investigation and trial were conducted, observing that serious procedural lapses resulted in a "travesty of justice."
A Bench of Justice Sanjay Kumar and Justice K. Vinod Chandran delivered the judgment on July 13, 2026, allowing the criminal appeal and setting aside both the Sessions Court's conviction and the High Court's order remanding the matter.
Background of the Case
The case arose from the death of the appellant's wife, who suffered burn injuries at her matrimonial home in April 2000 and later died during treatment. Her father subsequently alleged that she had been subjected to continuous dowry demands of ₹50,000 and cruelty by her husband and his relatives.
The Court noted that the same FIR eventually resulted in two separate final reports and two separate sessions trials involving 17 accused persons. While the husband was convicted in one trial, the remaining family members were acquitted, and another trial had already ended in acquittal for the parents-in-law.
Court Examines Procedural Irregularities
The Bench examined the unusual course adopted during the investigation. It found that the Superintendent of Police had directed the investigating officer to file a charge sheet against only two accused while keeping the investigation pending against the remaining persons.
The Court observed that such directions were beyond the authority of the Superintendent of Police. It clarified that the decision on whether to take cognizance of an offence ultimately rests with the Magistrate and not with a superior police officer.
"The formation of opinion as to whether or not there is a case to place the accused on trial is exclusively with the officer in charge of the investigation,"
the Bench observed while discussing the legal position governing police investigations and judicial cognizance.
After examining the evidence, the Supreme Court found several shortcomings in the prosecution's case.
The Bench noted that no postmortem examination was conducted despite the victim's death from burn injuries. It also found that the investigating officer had failed to properly collect hospital records, examine important medical witnesses, or effectively investigate events that occurred in Mirzapur and Allahabad after the victim was admitted to hospital.
The Court observed that the prosecution witnesses, who were largely close relatives of the deceased, repeatedly referred to an alleged demand for ₹50,000 but provided little specific evidence to support the allegation. According to the judgment, their statements amounted to a "soulless reiteration" of the dowry demand without supporting circumstances.
Defence Evidence Was Ignored
A significant factor that weighed with the Court was the defence evidence.
The husband produced medical records showing he had sustained burn injuries while attempting to save his wife. The defence also relied on hospital documents, treatment records, investment certificates in the joint names of the couple, insurance documents, and evidence that he had informed the victim's family shortly after the incident. Independent witnesses, including doctors and an Executive Magistrate, were also examined.
The Court also considered the existence of a dying declaration recorded before an Executive Magistrate in which the deceased stated that the burns were caused by an accidental kitchen fire while boiling milk and that none of her in-laws were responsible. Although the Bench said such a declaration had to be viewed cautiously because it was made while she was under the care of her husband and in-laws, it held that the declaration at least created a reasonable doubt when read with the remaining evidence.
"The prosecution has failed to establish the charges beyond reasonable doubt,"
the Bench observed, adding that trial courts should give equal attention to defence evidence and not approach it with suspicion merely because it comes from the accused.
Supreme Court's Decision
Allowing the appeal, the Supreme Court held that the prosecution had failed to prove continuous dowry demands, marital cruelty, or circumstances establishing dowry death. The Court also remarked that as many as 17 family members had been put through criminal proceedings despite the evidence being inadequate.
The Bench set aside the conviction recorded by the Sessions Court as well as the High Court's remand order, acquitted Brajesh Kumar @ Birjesh Kumar Singh of all charges, cancelled his bail bonds, and directed that he be released immediately if he was still in custody and not required in any other case.
Case Details:
Case Title: Brajesh Kumar @ Birjesh Kumar Singh vs. The State of Bihar
Case Number: Criminal Appeal No. 3117 of 2026 (@ Special Leave Petition (Crl.) No. 474 of 2026)
Judge: Justice Sanjay Kumar and Justice K. Vinod Chandran
Decision Date: 13 July 2026
