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2026 Supreme(SC) 591

SANJAY KUMAR, K. VINOD CHANDRAN
Gandadhipa Sahu – Appellant
Versus
State of Odisha – Respondent


Advocates appeared:
For the Petitioner(s): Mr. Kailash Vasdev, Sr. Adv. Mr. Kiran Kumar Patra, AOR Mr. Umrao Singh Rawat, Adv. Mr. Padamnav Chaudhary, Adv. Mr. Sanjay Kumar, Adv. Mr. Preetish Sahu, Adv. Ms. Abhilasa Pathak, Adv.
For the Respondent(s): Ms. Ankita Chaudhary, AOR Mr. Chand Kapoor, Adv. Mr. Shreyas Balaji, Adv. Ms. Vishakha Raghuram, Adv.

Judgement Key Points

Key Points: - Conviction under DP Act inconsistent with finding of no dowry demand; conviction under 498-A based on general and omnibus allegations challenged. (!) - Death by suicide; evidence shows sufficiency of poisoning signs but question whether cruelty/dowry demands were proven; trial court and High Court findings discussed. (!) (!) - Court acquits appellant; 498-A evidence found lacking; no specific instances of dowry demand or targeted acts; reliance on letters deemed unreliable due to handwriting/production issues. (!) (!) - Oral testimony regarding dowry demand described as general/omnibus; no specific day/time or persons. (!) (!) - No requirement of dowry demand to attract 498-A, but evidence did not establish any unlawful demand or cruel acts. (!) - High Court reduced sentences and used Probation of Offenders Act; appellate court reverses such rulings and acquits. (!) (!) - Appellant to be released forthwith unless required in other cases. (!) (!)

What is the scope of 498-A IPC in relation to dowry demands and cruelty when no specific or direct demand is proven?

What are the consequences of evidence failing to prove dowry demand or cruel acts under Section 498-A and DP Act in a case of suspected dowry-related suicide?

What is the Supreme Court's ruling regarding conviction under DP Act inconsistent with findings of no dowry demand and the sufficiency of oral testimony to establish 498-A?


JUDGMENT :

K. VINOD CHANDRAN, J.

Leave granted.

2. Suicide for sure, whether on volition or driven to it by the husband and in-laws, was the question posed before the trial court. The husband and the in-laws were the accused charged of continuous torture and harassment on demands of dowry. The trial court acquitted the accused of the charges under Section 304-B of the Indian Penal Code, 1860 (the IPC) finding that there is no evidence on the aspect of demand of dowry and that the letter produced, alleged to be a demand made by the father-in-law, A2, was not proved. However, relying on the oral testimony of PW2 to PW5 and the letters said to have been written by the deceased to her brother, PW3, and her father, torture was found to have been meted out to the deceased by the accused for non-fulfilment of unlawful demands. The finding was despite holding that there were only general and omnibus statements made without any specific or definite instances or the particular day or time having been pointed out. The trial court convicted the accused and sentenced the accused to three years rigorous imprisonment (RI) and a fine of Rs.5,000/- with default sentence of three months RI under Sectio

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