Vague Dowry and Cruelty Allegations Cannot Sustain Dowry Death Case Against Husband: Supreme Court Quashes FIR

The appellant married the complainant's daughter on 03.01.2021, and the couple moved to Toronto, Canada in February 2022 (para 3). On 11.06.2023 she died by suicide; a handwritten note recovered from their apartment spoke of her struggle to find a job (para 4). Her father, respondent No. 2, then lodged FIR No. 212/2023 at Satara Police Station, Aurangabad, against the appellant, his parents and sister, alleging demands for gold as dowry and abuse (paras 2, 5). The Canadian coroner and Toronto Police found no sign of struggle or foul play (paras 6-7). On 08.01.2025 the Bombay High Court, Aurangabad Bench, quashed the case against the relatives but not against the husband; a chargesheet followed (paras 2, 9-10).

Between the marriage and the death there was not even a whiff of any dowry allegation; the allegations about 2021 and 2022 surfaced only in the FIR lodged after it, and no complaint had been made to any authority, Indian or Canadian (para 38). The suicide note attributed her stress to her employment status and studies and mentioned neither the appellant nor his family; dowry harassment would naturally have found mention in it (para 39). By the complainant's own Section 161 statement, the 15 tolas of gold were given to both spouses as a wedding gift, which cannot be construed as dowry; the Diwali gifts were plausibly customary and had no cause-and-effect link with a death nearly a year later (paras 40-41). A Rs. 1,00,000 transfer from her brother coincided with flight bookings and could not be singled out (para 42). Without evidence of a dowry demand or its nexus with the suicide, Section 304B was not attracted (paras 41-42). The hurt and intimidation allegations were vague and omnibus, no instance of cruelty was shown, and calling her ‘stupid’ and ‘useless’ at best reflects temperament (paras 43-45). Bhajan Lal categories (1), (2), (3), (5) and (7) applied (paras 46-47).