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2026 Supreme(AP) 157

IN THE HIGH COURT OF ANDHRA PRADESH AT AMARAVATI
K.SURESH REDDY, SUBBA REDDY SATTI, JJ.
Malkari Radha Bai and Another – Appellant
Versus
State of Andhra Pradesh – Respondent
Criminal Appeal Nos. 2301, 2600 of 2018
Decided On : 05-01-2026

Advocates Appeared:
For the Appellant : A. Gayathri Reddy
For the Respondent: Marri Venkata Ramana

The court mandated that for a conviction under Section 304-B IPC, the prosecution must demonstrate a proximate link between cruelty and the death, which was found lacking in this case.

Headnote:(A) Indian Penal Code, 1860 - Sections 498-A and 304-B - Appellants accused of cruelty and dowry death - Allegations of harassment for additional dowry leading to deceased's suicide by railway track - Trial court conviction under 304-B and 498-A IPC set aside due to failure of prosecution to prove guilt beyond reasonable doubt - Key testimonies found insufficient and contradictory. (Paras 5, 30)

(B) Burden of proof - Prosecution must definitively connect accused with the crime and demonstrate harassment or cruelty soon before death - Essential to establish 'proximate' link between alleged acts and the incident. (Paras 18, 19)

Facts of the case:
The deceased, married for six years, allegedly subjected to continuous harassment by her in-laws regarding dowry and childbirth. Death occurred under suspicious circumstances shortly after. (Paras 4, 7)

Findings of Court:
The evidence against the accused lacked credibility and failed to connect them to the death of the deceased, leading to quashing the convictions. (Paras 29, 30)

Issues: Whether the prosecution established the elements of murder and cruelty 'soon before' the death.

Ratio Decidendi: The court highlighted the need for a close connection between acts of cruelty and the death, dismissing charges due to lack of corroborative evidence to support claims. (Paras 19, 22)

Result: Appeals allowed, convictions set aside, and accused acquitted.

Table of Content
1. summary of case background and charges. (Para 1 , 2 , 3 , 4)
2. details of trial outcomes and appeals. (Para 5 , 6 , 7 , 8 , 9)
3. arguments presented by both parties. (Para 11 , 12 , 13)
4. interpretation of key legal provisions. (Para 15 , 16 , 17 , 18 , 19 , 20 , 21 , 22 , 23)
5. analysis of evidence and credibility. (Para 24 , 25 , 26 , 27 , 28 , 29)
6. conclusion and outcome of appeals. (Para 30 , 31)

JUDGMENT :

SUBBA REDDY SATTI, J.

1. 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 .

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 -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 -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 lead happy marital life with the deceased. However

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