News Citation : 2026 LN (HC) 38
Bilaspur, January 13, 2026 : The High Court of Chhattisgarh has acquitted a man convicted nearly two decades ago for dowry death and cruelty, holding that the prosecution failed to prove the core legal requirement of cruelty or harassment linked to dowry demands soon before the woman’s death.
In a judgment delivered on January 13, 2026, Justice Rajani Dubey allowed the criminal appeal filed by Uday Bharti, who had been sentenced in 2007 to seven years’ rigorous imprisonment under Section 304B of the Indian Penal Code and three years under Section 498A. The trial court had earlier convicted him while acquitting his mother and sister. The High Court, after reappreciating the evidence, set aside the conviction and extended the benefit of doubt to the appellant.
The case related to the death of Seema, who died by hanging in November 2006, within seven years of her marriage. Medical evidence on record confirmed that the death was suicidal and caused by asphyxia due to hanging. There was no challenge by the prosecution to this finding. The appeal therefore turned on whether Seema had been subjected to cruelty or harassment for dowry soon before her death, an essential ingredient for offences under Sections 304B and 498A IPC.
The prosecution relied primarily on the testimonies of the deceased woman’s close relatives, including her mother, father, brother, and brother-in-law, who alleged harassment and demands for money. However, the High Court noted serious inconsistencies, omissions, and contradictions in their statements. Importantly, no complaint or report had ever been lodged during Seema’s lifetime despite claims that she had disclosed harassment. The court also took note of admissions that no family meeting or intervention was ever attempted, and that some alleged payments of money were unsupported by documentary proof.
The only independent witness, the landlord of the couple, stated that they lived normally and did not report any dowry-related cruelty. While she mentioned that the husband consumed alcohol and that this upset the deceased, the court held that such conduct, by itself, does not meet the legal threshold of cruelty connected to dowry demand.
Relying on settled principles laid down by the Supreme Court, the High Court reiterated that vague or general allegations are insufficient to sustain a conviction for dowry death. The law requires clear proof that cruelty or harassment for dowry occurred soon before the woman’s death. Finding that this standard was not met, the court concluded that the prosecution had failed to establish guilt beyond reasonable doubt.
As a result, the appeal was allowed, and Uday Bharti was acquitted of all charges. Since he was already on bail, the court directed him to furnish a personal bond of Rs 25,000 with a surety, as required under law, to ensure his appearance if the matter is taken further before the Supreme Court.
Case Reference : CRA No. 994 of 2007: Uday Bharti, S/o Bitthal Bharti, Raipur v. State of Chhattisgarh; for the appellant Mr. Pawan Kesharwani, Advocate, and for the respondent/State Ms. Sunita Sahu, Public Prosecutor.