Prosecution must prove guilt beyond reasonable doubt in dowry death cases; lack of sufficient evidence to establish ongoing harassment led to acquittal.

JUDGMENT :

Subba Reddy Satti, J.

Since both the Criminal Appeals arise out of the same Sessions Case, i.e., S.C.No.218 of 2017, on the file of the Court of VI Additional Sessions Judge, Anantapuramu, at Gooty, they are heard together and disposed of by way of this common judgment.

2. Accused Nos.2 & 3 in the above Sessions Case filed Criminal Appeal No.2301 of 2018 and accused No.1 filed Criminal Appeal No.2600 of 2018. They were tried by the learned Additional Sessions Judge under the following charges:

The first charge was under Section 498-A IPC.

The last charge was under Section 304-B r/w 34 IPC or 302 IPC.

3. For the sake of convenience, the parties to this common judgment are referred to as they were arrayed in S.C.No.218 of 2017.

4. Substance of the charge is that A-1 being husband, A-2 and A-3 being in-laws of M.Lakshmi Rajyam @ Rajya Lakshmi (hereinafter referred to as deceased), subjected her to cruelty for want of additional dowry; that the deceased died on 04.03.2016 at about 7.00 p.m. by falling under a train, within 7 years of marriage; the accused subjected the deceased to cruelty soon before her death and thus, committed offences punishable under Sections 498-A, 304-B r/w 34 or 302 IPC.

5. After completion of trial, the learned Additional Sessions Judge convicted accused No.1 under Section 304-B I.P.C. and sentenced him to suffer imprisonment for ‘LIFE’. The learned Additional Sessions Judge further convicted accused No.1 under Section 498-A I.P.C. and sentenced him to suffer Simple Imprisonment for three years and also to pay a fine of Rs.1,000/-, in default to suffer Simple Imprisonment for one month. The learned Additional Sessions Judge further convicted accused Nos.2 and 3 under Section 304-B I.P.C. and sentenced each one of them to suffer Simple Imprisonment for a period of seven years. The learned Additional Sessions Judge also convicted accused Nos.2 and 3 under Section 498-A I.P.C. and sentenced them to suffer Simple Imprisonment for a period of one year and also to pay a fine of Rs.1,000/- each, in default to undergo Simple Imprisonment for one month. Both the substantive sentences were directed to run concurrently.

6. Learned counsel for the appellants field a memo vide USR No.141377/2025 stating that appellant No.2/accused No.3 in Crl.A.No.2301 of 2018 died pending the appeal. In view of the said fact, Crl.A.No.2301 of 2018, by order dated 18.12.2025, was dismissed as abated insofar as appellant No.2/accused No.3 is concerned. Both the appeals are taken up for hearing insofar as accused Nos.1 and 2 are concerned.

7. Case of the prosecution, as emanated from the evidence, briefly, is as follows:

(i) P.W.3 is the father, P.W.4 is the brother, and P.W.10 is the paternal uncle of the deceased, respectively. A-1 is the husband, A-2 and A-3 are in-law of the deceased respectively. The marriage between the deceased and A-1 was solemnised about 6 years prior to the date of incident. At the time of marriage, P.W.1 gave Rs.5,00,000/- and 150 grams of gold and other household articles towards dowry. One month after the marriage, all the accused started harassing the deceased to bring gold ornaments and Pattu clothes towards ‘Vadibiyyam’ every year from her parents. The accused also harassed the deceased, as she failed to conceive children. P.W.1 took the deceased to the hospital in Hyderabad, where fertility tests were conducted, and no defect was found with the deceased. P.Ws.3 and 10 went to the house of accused and gave Rs.50,000/- to A-1 and chastised them to le