Ram Pyarey vs. State of Uttar Pradesh, Criminal Appeal No. 1408 of 2015, Supreme Court of India, Judgment dated January 9, 2025, [2025 INSC 71].
- ByPravleen Kaur --
- 15 Jun 2025 --
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The Supreme Court of India, in Ram Pyarey vs. State of Uttar Pradesh [Criminal Appeal No. 1408 of 2015, decided January 9, 2025; 2025 INSC 71], acquitted the appellant, who was convicted under Sections 306 (abetment of suicide), 498A (cruelty by husband or relatives), and Section 4 of the Dowry Prohibition Act, in a dowry death case dating back to 1990.
Facts and Background
The deceased was married to Ram Sajeevan, and the appellant Ram Pyarey was the deceased’s brother-in-law. The father of the deceased lodged an FIR alleging dowry harassment and demands for a buffalo and gold chain by the husband, in-laws, and the appellant. The deceased allegedly died by setting herself on fire. The trial court acquitted all accused under Section 304B (dowry death) but convicted them under Sections 306 and 498A IPC. The Allahabad High Court upheld these convictions.
Legal Issues
Whether the prosecution proved the ingredients of abetment of suicide and cruelty under Sections 306 and 498A IPC.
The applicability of Section 113A of the Indian Evidence Act, which allows courts to presume abetment of suicide if cruelty or harassment is established.
The sufficiency and cogency of evidence regarding harassment or instigation by the accused.
Supreme Court’s Reasoning
The Court distinguished between Sections 113A and 113B of the Evidence Act, noting that while Section 113B mandates presumption of dowry death upon proof of certain conditions, Section 113A allows only a discretionary presumption of abetment of suicide, which requires cogent evidence of cruelty or harassment.
The Court found that there was no cogent evidence against the appellant to establish cruelty, harassment, or instigation to suicide. Mere allegations without proof of active aiding or instigating cannot invoke the presumption under Section 113A. The prosecution failed to demonstrate any direct role of the appellant in the deceased’s death.
Conclusion
The Supreme Court set aside the convictions and acquitted Ram Pyarey, holding that:
Presumption of abetment of suicide under Section 113A cannot be invoked without clear, cogent evidence of harassment or instigation.
Mere allegations or suspicion are insufficient to sustain conviction.
The benefit of doubt must be given to the accused where evidence is lacking.
The judgment reinforces the principle that criminal liability must be based on proof beyond reasonable doubt and that statutory presumptions have limits.
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