The Chhattisgarh High Court on October 27, 2025, affirmed a conviction under Section 304-B of the Indian Penal Code in the case arising from the death of 23-year-old Pranjal Rathore, while quashing an earlier conviction for murder under Section 302. The two-judge bench reviewed the trial court’s findings, the medical evidence and family testimony, and concluded that the facts fit the statutory scheme for a dowry death, but did not support a parallel conviction for murder without clearer proof of homicidal intent.
The case began when Pranjal died within seven months of her marriage in October 2020. Her father, mother and sister told court that she had been repeatedly harassed over a dowry demand of Rs. 3 lakh and that she returned to her matrimonial home during Navratri only to be sent back under pressure. The local police recorded an initial merg intimation and later registered an FIR after the body was found hanging. A forensic postmortem found multiple injuries, fracture of the hyoid bone and ligature marks; the postmortem surgeon concluded that the cause of death was asphyxia due to strangulation and that the death was homicidal in nature.
At trial the sessions court convicted the husband and the mother-in-law for dowry death under Section 304-B read with Section 34, and also convicted them under Section 302 read with Section 34, awarding life imprisonment and additional sentences to run concurrently. On appeal, the High Court reviewed both the factual record and governing precedent on how dowry-death provisions interact with ordinary homicide charges.
The High Court upheld the trial court’s finding that the death occurred within seven years of marriage, that Pranjal had been subjected to cruelty and harassment in connection with a dowry demand, and that the death occurred otherwise than under normal circumstances elements that bring Section 304-B and the presumption in Section 113-B of the Evidence Act into play. On that basis, the court affirmed the conviction under Section 304-B.
However, the bench found the simultaneous conviction under Section 302 unsustainable. Drawing on Supreme Court precedents, the High Court explained that dowry-death and murder provisions occupy different legal spaces. Where the statutory ingredients of dowry death are established, the law treats the husband or relative as having caused the death in the special sense created by Section 304-B; that does not by itself substitute for the specific proof of intent or direct participation required to maintain a conviction for murder. In this case, the trial court had relied on presumptions under the Evidence Act and the fact that the deceased lived with the accused, but it did not record an independent finding of intentional homicide or identify specific direct participation that would justify a Section 302 conviction. For these reasons the High Court set aside the murder conviction while leaving the dowry-death conviction intact.
The judgment had immediate practical consequences. One appellant, the husband, remained in custody to serve the sentence imposed under Section 304-B. The mother-in-law, who had been on bail, had her bail bond cancelled and was directed to surrender forthwith or be taken into custody to serve the remainder of the sentence. The court also noted that one of the originally accused parties had died during the pendency of the appeal and that portion of the appeal had been abated.
Beyond the case outcome, the High Court ordered circulation of the judgment to all sessions courts in the state so judges and prosecutors handle dowry-death charges and trials with due regard to the statutory framework and settled judicial interpretation. The court emphasized careful framing of charges and the limits on stacking mutually exclusive convictions without clear supporting material. The registry was also directed to forward certified copies of the judgment to jail authorities and to inform the appellants of their appellate rights, including access to legal aid.
This ruling underscores a few important points for how courts approach deaths within marriage that involve alleged dowry harassment. Where the statutory conditions for a dowry death are satisfied, the law gives rise to a presumption linking relatives to the death in that statutory sense. At the same time, if the prosecution seeks to prove murder it must present independent, cogent evidence of direct participation or intent. The High Court’s decision in this case preserves the dowry-death conviction while reinforcing procedural and evidentiary boundaries around charging and convicting for murder.
Citation : 2025 Local Law (CG) 837
Case Details : CRA No. 1530 of 2022, Deepak Kumar Rathore and Others vs State of Chhattisgarh, For Appellants : Mr. Rajeev Kumar Dubey, Advocate with Ms. Maya Chaturvijani, Advocate. For Respondent/State : Mr. Hariom Rai, Panel Lawyer
Nutural Citation : 2025:CGHC:52155-DB
