The Allahabad High Court has granted compensation of ₹2 lakh to a man who was acquitted in a dowry death case, holding that the State’s appeal against his acquittal amounted to a vexatious criminal prosecution. The Court observed that the State had directed the public prosecutor to file an appeal without proper application of judicial mind, thereby jeopardizing the life and liberty of the accused for a second time despite the presumption of innocence established by the trial court. The bench, comprising Justices Siddharth and Avnish Saxena, found that such conduct on the part of the State necessitated remedial action through compensation.
The case stemmed from the death of the accused's wife, who died by suicide through hanging. It was alleged that the suicide was linked to dowry demands and the refusal of the husband to acknowledge a child born to the deceased. A suicide note was recovered, and the post-mortem confirmed hanging as the cause of death. The accused was charged under Sections 498A, 304B, 504, and 506 of the Indian Penal Code, as well as Sections 3 and 4 of the Dowry Prohibition Act. The trial court, however, acquitted him after a detailed evaluation of the evidence.
Despite the acquittal, the State appealed the decision, asserting that the trial court had failed to properly consider witness testimony regarding alleged dowry demands made shortly before the death. The High Court rejected the appeal, affirming the findings of the trial court and reiterating the principle of presumption of innocence. It emphasized that appellate courts must not interfere with acquittals unless the judgment is shown to be perverse or irrational.
The Court relied on settled legal principles, including those established in earlier Supreme Court rulings, which hold that if two views are possible on the evidence—one pointing to guilt and the other to innocence—the one favoring acquittal must be adopted. It noted that acquittals should not be overturned without compelling and substantial reasons. The High Court also observed that the trial court had correctly examined the role of witnesses, the authenticity of the suicide note, and the context of the woman’s earlier marriage, and had found no sufficient basis to convict the accused.
Criticizing the State’s decision to pursue the appeal, the Court remarked that applications under Section 378 of the Code of Criminal Procedure for leave to appeal should be filed with caution and only in exceptional cases. The mere availability of an appeal should not be treated as justification for challenging every acquittal, especially where the trial court’s findings are reasoned and supported by the record.
In light of the repeated legal trauma faced by the accused, the Court held that he was entitled to compensation. It stated that exposing a person to a second round of criminal litigation without substantial grounds constitutes a serious infringement of rights and an abuse of legal process. Accordingly, the Court directed the State to pay ₹2 lakh to the accused as compensation for the unwarranted harassment and to uphold the principle that justice must be not only done but seen to be done.
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