Karan Singh Vs State of Haryana

AUTHOR: RUCHI RAINA, GJ ADVANI LAW COLLEGE, MUMBAI

Title: Karan Singh Vs State of Haryana

Date of Judgement: 31st January,2025

Citation: 2025 INSC 133

Bench: Abhay S Okha Justice Ujjal Bhuyan

Parties: Appellant: Karan Singh 

              Respondent: State of Haryana

Can a person be convicted for dowry harassment without substantial evidence? 

The case of Karan Singh vs. State of Haryana (2025) sparks a fundamental debate on justice and judicial accountability. Following the tragic death of his wife, Karan Singh was accused of dowry harassment and subjected to legal proceedings under sections 304B and 498A of the IPC. The Supreme court not only overruled the decision of both the Sessions court and the High court but also reflected upon the failure of state judicial academies in training judges  implicitly acknowledging that lower courts often operate under societal pressure rather than strict adherence to legal principles.

Section 304B and Section 498A of Indian Penal Code

Legal Provisions:

304B of Indian penal Code (Section 80 of Bhartiya Nyaya Sanhita, 2023) address two main elements which are listed as follows:

• Death of a woman should have occurred under normal circumstances within the early 7 years of marriage. 

• Soon before the death she should have been subjected to harassment and cruelty in relation with any demand for dowry. 

Based on the elements listed above If the husband or his relatives are presumed guilty of the offense section 304B of Indian Penal Code can be invoked against them. 

498A of Indian Penal Code (Section 86 of Bhartiya Nyaya Sanhita, 2023) states that :

If a husband or his relative subjects a woman to cruelty, they shall be punished with imprisonment for up to three years and a fine.

Cruelty can be defined as:

1. Any injury that would likely cause the woman to cause grave injury or danger to her life, limb, or health (mental or physical) or commit suicide. 

2. Any form of harassment with the intention to coerce the woman or her relatives to meet unlawful demands for property or valuable security, or due to her or her relatives' inability and failure to meet such demands. 

• The appellant, Karan Singh married his late wife Asha Rani in 1996.

• In 1998 merely 2 years into the marriage his wife tragically committed suicide. 

• The medical examination confirms the cause of death as asphyxia due to hanging. 

• Following the incident Karan Singh and his family are subjected to legal proceedings under section 304b and 498A of the Indian Penal Code. 

• The trial court acquits the parents but Karan Singh is convicted and sentenced to seven years of rigorous imprisonment under section 304B and 1 year of rigorous imprisonment under section 498A of the Indian Penal Code (IPC) along with a fine of ₹500 with a default sentence of 3 months.

• In 2010, the High Court upheld the conviction of the trial court.

Key Witnesses:

PW-6: Inder Kala, mother of the Asha Rani

PW-7: Parvinder Kumar brother of the Asha Rani

PW-8: Ram Singh maternal uncle of Asha Rani

Both the Trial court and the high court found the testimonies of the mother and uncle trustworthy and reliable

issues raised before the Supreme Court: 

• Whether the prosecution be able to establish essential ingredients under section 304-B of the Indian Penal Code 

• Whether there is sufficient evidence to prove that the deceased wife was subjected to cruelty by the appellant under sec 113B of the Indian Evidence Act 

• Whether there is sufficient evidence against the appellant to convict him under section 498A of IPC

Appellant:

The learned counsel appearing on behalf of the appellant contended that all allegations made by the witnesses regarding the demand of dowry are material omission. 

Relying on the judgment of Charan Singh v. State of Uttarakhand (2023) the learned counsel submitted that there is no evidence to prove that soon before the death the wife was subjected to cruelty or dowry demands by the husband. In the absence of legal evidence against the appellant, the court should have acquitted him. 

Respondent: 

Prosecution's case: The prosecution relied on testimonies of the 2 witnesses, the deceased's brother and mother, to establish that she was subjected to cruelty and harassment related to dowry demand. 

According to the testimony of the witnesses 10-12 days prior to the incident the deceased had shared her concerns regarding the demand of Rs 60,000 made by the appellant for purchasing a jeep. 

The prosecution contended that based on the Presumption under section 113-B of the Indian Evidence Act the appellant had caused the death of his wife. 

The following observations were made by the court:

• No Evidence of dowry demand: There is no credible source or evidence to prove that the appellant and his family demanded dowry from the deceased. 

• Omissions and Contradiction in testimonies:

The Supreme Court observed that the testimonies of both the witnesses i.e. the mother (PW-6) and brother (PW-7) had omitted. 

The testimonies of witnesses alleging dowry demands made by the appellant and his family (for things like cash, a jeep, and household items) were not raised in initial statements taken by police which instigates a reasonable doubt on their reliability. 

• Absence of substantial proof of cruelty:

offences of cruelty and dowry demands must be proven to have occurred ‘soon before’ the death of the victim. However, in the present case, there is no substantial evidence to prove that the deceased was subjected to any form of harassment or cruelty before her death, an essential element for conviction under section 304B of the Indian Penal Code. 

• Misapplication of section 304B IPC;

While it is pertinent to note that section 304B Carries a presumption against the husband it shouldn't override the necessity to establish fundamental elements of crime beyond a reasonable doubt. 

Based on the above findings the Supreme Court overruled the decisions of trial court and high court and acquitted the appellant. 

The Supreme Court's remark, "It is for the State Judicial Academies to step in. Perhaps this is a case of moral conviction," highlights the need for better judicial training. The judgment implicitly acknowledges that lower courts often operate under societal pressure rather than strict adherence to legal principles.

While laws concerned with the protection of women against dowry harassment remain to hold significant importance, judicial objectivity must never be compromised in the name of social justice.  

It is imperative to note that there is an urgent need for systemic reforms so that presumptions of favouritism among victims do not lead to unlawful and wrongful convictions of innocent individuals. 

To prevent miscarriage of justice in the future judicial academies must educate judges on nuanced interpretation of laws. 

The principle of natural justice must be based on evidence, not on mere presumptions and societal pressure. 

Presumptions are anathema to justice dispensation. Presumptions and assumptions are byproducts of subjective biases and prejudices that have no place in judicial determinations. In Karan Singh's case, judicial impropriety, if not outright incompetence, destroyed the life of the individual, and the case is not a lone instance of a miscarriage of justice. Should this injustice be talked about and written about for a few days and forgotten thereafter? Who will assume responsibility for stemming the rot?