The Bombay High Court's Nagpur Bench has acquitted Pravin Babanrao Yawle and his father Babanrao Govindrao Yawle of charges under Sections 498-A and 304-B read with Section 34 of the Indian Penal Code (IPC), 1860. The lower court had convicted them for subjecting Pravin's wife, Pooja, to dowry-related cruelty, leading to her death by burns in 2013. However, the High Court ruled that the evidence presented was insufficient to establish a live connection between the alleged harassment and her death, resulting in the benefit of doubt being given to the accused.

1. Background:

   • The marriage between Pravin Yawle and Pooja took place on 10th February 2011.
   • For 4-5 months post-marriage, Pooja was treated well, but later, Pravin and his father allegedly demanded Rs. 50,000 in dowry.
   • Pooja’s family promised to pay after selling their soybean crop, but her treatment reportedly worsened.
   • On 1st August 2013, Pooja was found dead from burn injuries, and her family accused the in-laws of dowry-related cruelty.

2. Trial Court's Decision:

   • In November 2021, the Additional Sessions Judge convicted Pravin and Babanrao under Sections 498-A and 304-B, sentencing them to rigorous imprisonment.
   • However, two other accused, including Pooja’s mother-in-law and brother-in-law, were acquitted due to lack of evidence.

3. Appeal and Acquittal:

   • The High Court found inconsistencies and discrepancies in the testimonies related to the demand for dowry and cruelty.
   • The court noted that no specific role was attributed to the accused, and the allegations appeared omnibus and vague.
   • There was no evidence of harassment or cruelty after the settlement meeting between March and April 2013.
   • The High Court also emphasized that the prosecution failed to prove a direct nexus between the cruelty and Pooja’s death, which occurred four months later.

Acts and Sections Discussed:

1. Section 498-A IPC: Deals with cruelty by husband or relatives, particularly in connection with dowry.
2. Section 304-B IPC: Pertains to dowry deaths where the woman’s death occurs under unnatural circumstances within seven years of marriage.
3. Section 34 IPC: Establishes criminal liability for acts done in furtherance of common intention.
4. Section 113-B Indian Evidence Act: Presumption of dowry death, placing the burden on the accused to rebut the claim of cruelty related to dowry demands.

Ratio Decidendi:

The court concluded that the prosecution failed to establish a proximate and live link between the alleged cruelty and Pooja’s death. The evidence provided lacked consistency, and the vague and omnibus allegations against the accused failed to meet the legal threshold for conviction. The court stressed that mere suspicion or the fact of suicide alone cannot warrant a conviction for dowry death without clear, cogent, and specific evidence. As such, the accused were given the benefit of doubt and acquitted.