Lalita vs. Vishwanath
Citation: 2025 INSC 307; Bench: Justice J.B. Pardiwala, Justice R. Mahadevan
Background
This case arose from the tragic suicide of Dev Kanya, who was married to Vishwanath (Respondent No. 1) for about one and a half years. Lalita, her mother, alleged that her daughter was subjected to persistent harassment and cruelty by her husband, his parents, and his first wife, which drove her to take her own life by jumping into a well. The deceased’s father initially lodged the First Information Report (FIR), but he passed away before the trial commenced.
Trial and High Court Proceedings
The police investigation included witness statements, an inquest, and forensic analysis. The post-mortem confirmed death by drowning. The Trial Court, after evaluating oral and documentary evidence, convicted all four accused under Sections 306 (abetment of suicide) and 498A (cruelty) read with Section 34 IPC, sentencing them to ten years of rigorous imprisonment and a fine.
On appeal, the Bombay High Court (Aurangabad Bench) reversed the convictions, acquitting all accused on the grounds that the evidence did not establish the requisite standard for abetment of suicide. The State did not challenge the acquittal; the deceased’s mother appealed to the Supreme Court.
Supreme Court’s Analysis
Evidentiary Value of FIR:
The Court clarified that if the informant of an FIR dies a natural death unrelated to the complaint, the contents of the FIR are inadmissible as substantive evidence unless corroborated or treated as a dying declaration. The investigating officer cannot prove the FIR’s contents merely by deposition in such cases.
Presumption under Section 113A Evidence Act:
The Court reiterated that a presumption of abetment of suicide by a married woman within seven years of marriage arises only if there is clear evidence of cruelty. However, this presumption is rebuttable and does not dispense with the need for cogent proof of abetment.
Assessment of Harassment and Cruelty:
The Supreme Court found that while there was evidence of some discord, the prosecution failed to prove persistent harassment or cruelty of such gravity as to instigate suicide. Mere allegations or general evidence of strained relations are insufficient for conviction under Section 306 IPC.
Acquittal Upheld:
The Court concluded that the High Court was justified in acquitting the accused, as the evidentiary standard for abetment of suicide was not met and the FIR could not be relied upon as substantive evidence in the absence of corroboration.
Significance
This judgment clarifies the evidentiary limitations of FIRs when the informant is deceased, the strict requirements for presumption of abetment to suicide, and the high threshold of proof necessary for conviction under Section 306 IPC. The decision upholds the principle that criminal convictions cannot rest on uncorroborated or inadmissible evidence.
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