Factual Background 

In the Matter of State of Haryana v. Darshan Lal appeal contesting the validity of the trial court’s decision from November 29, 2006, which exonerated the respondents of accusations brought against them under Section 306/34 of the Penal Code, 1860. In 1984, the victim and the respondent were married. After seven days, the deceased said her spouse had filed for divorce and she had to return home. She was coerced into providing further dowry by the respondent and his family. The dead was assaulted and mistreated after complaining that her spouse was seeing another lady. If the money wasn’t paid in full within four days, they threatened to kill her. They demanded 3 lacs. According to the deceased’s father, she was tortured and ingested deadly substances before she committed suicide. The State of Haryana has chosen to file an immediate appeal following the fast-track court’s decision in favour of the respondent.

Conclusion of the Court 

Justice N.S. Shekhawat J. of the Punjab and Haryana High Court’s single-judge bench dismissed the appeal and maintained the Trial Court’s ruling, stating that the prosecution witness had made broad, imprecise accusations against the respondents and had failed to stand up to cross-examination.

The prosecution witness failed the cross-examination test and, in the opinion of the court, made broad, imprecise accusations against the respondents. According to the Court, the fact that a wife committed suicide while living with her husband and in-laws did not automatically render them responsible for pressuring her to take her own life. Additionally, it stated that there was “no specific or convincing evidence against her in-laws and her husband to prove their complicity in the commission of the crime. The court emphasised that conviction cannot stand in the absence of a positive act by the accused since abetment entails a mental process of knowingly inciting or assisting someone to do something. The document continued by stating that men’s rea to commit the crime is a sine qua non to find a defendant guilty under Section 306 IPC. As a result, the Court rejected the State’s appeal request and maintained the Trial Court’s judgment to discharge the respondents.

CASE NAME – State of Haryana v. Darshan Lal, 2023 SCC OnLine P&H 445