‘Husband, other family members not roped in as per usual tactics’: SC confirms conviction of mother-in-law in abetment to suicide case

New Delhi: The Supreme Court has rejected a plea by a woman in her 70s against her conviction and three-year jail term in a case of abetment of suicide of her pregnant daughter-in-law in 1998, stating that it is one of the rare cases where the husband or his other family members have not unnecessarily been roped in as accused— a usual tactic adopted in similar cases.

A bench of Justices Vikram Nath, Sanjay Karol and Sandeep Mehta said the complainant has displayed honesty, which reflected on the overall conduct of the prosecution.

The court dismissed an appeal filed by Shakuntla Devi against the High Court's 2018 judgment, which acquitted her of the charges of dowry death but held her guilty of the abetment to suicide of her daughter-in-law Kusum and sentenced her to three years’ imprisonment, owing to her old age.

"We firmly believe that the awarded sentence balances the interest of justice quite equitably. Therefore, we do not find any reason to interfere in the order," Justice Nath wrote in the April 25, 2025 judgment on behalf of the bench.

Considering her appeal, the bench said the trial court found the 17-year-old brother of the deceased woman—who accompanied her to the matrimonial home after she alleged the mother-in-law demanded Rs 25,000 and a gold chain—has narrated the entire facts in a very natural way.

"This fact has not gone unnoticed by us, as well as the fact that he has given an account of events in a very natural manner that does not seem exaggerated or untruthful in any manner," the bench said.

In fact, the court pointed out, the said witness has also been very honest about his lack of knowledge regarding the administration of poison to his sister and has clearly stated that he was not an eyewitness to the exact act and, thus, has made no statement unnecessarily alleging that the accused herself had administered such poison to the deceased, which caused her death.

"There is an element of honesty and fairness in his statement throughout, which lends it much credibility," the bench said.

The court also noted from the statements of other witnesses, as well as the FIR, that it becomes apparent the family members of the deceased have been very precise in their allegations against the appellant.

"Beginning from the point of registration of the FIR and throughout the course of trial, it has been stated consistently that it was solely the mother-in-law of the deceased, i.e. the appellant herein, who used to physically and verbally abuse the deceased with regard to demand for dowry. The specific demand that was made by the accused time and again has also remained the same throughout all the statements," the court said.

With regard to the offence of abetment to suicide under Section 306 of the IPC, the court said it is settled that the offence requires an active act or omission which led the deceased to commit suicide, and this act or omission must have been intended to push the deceased into committing suicide.

The court held that the facts of the case make it abundantly clear that the deceased was repeatedly tortured and abused by the accused on account of dowry demands to the extent that the deceased had to return to her parental home seeking refuge.

It was only on the assurance of her parents that the deceased went back to her matrimonial home, hoping that the events would take an upturn once her parents settled the matter of dowry with the appellant-accused, the bench said.

"However, the abuses hurled at the deceased by the appellant on the day of the incident, i.e. May 4, 1998, unfortunately acted as the straw that broke the camel’s back and led her to committing suicide. Therefore, given the factual matrix, the guilt of the appellant under Section 306 of the IPC has been proved beyond reasonable doubt," the bench said.