Ramesh Kumar vs State of Chhattisgarh (2001)
Ramesh Kumar vs State of Chhattisgarh (2001)
Citation & Bench
Case Name: Ramesh Kumar v. State of Chhattisgarh
Citation: (2001) 9 SCC 618 / AIR 2001 SC 2594
Court: Supreme Court of India
Bench: Dr. A.S. Anand, CJI; R.C. Lahoti & K.G. Balakrishnan, JJ.
Date of Judgment: 17 October 2001
1. Facts of the Case
Seema Devi, the wife of Ramesh Kumar, was married on 23 June 1985.
On 17 June 1986, she committed suicide by setting herself on fire.
Before her death, she wrote a suicide note and a letter to her husband stating she alone was responsible and that no one else was to blame.
She also made a dying declaration before an Executive Magistrate reiterating that no one was responsible for her death.
Ramesh Kumar was charged under Section 306 (abetment of suicide) and Section 498-A IPC (cruelty by husband or relatives).
The Trial Court convicted him under both Sections, sentencing 7 years under Section 306 and 2 years under Section 498-A.
The High Court upheld the convictions, which led to the Supreme Court appeal.
2. Legal Issues
Whether Ramesh Kumar instigated Seema Devi’s suicide, attracting liability under Section 306 IPC.
Whether Ramesh Kumar’s acts constituted cruelty under Section 498-A IPC.
The applicability of Section 113-A of the Indian Evidence Act, which presumes abetment of suicide in certain cases within seven years of marriage.
3. Supreme Court’s Analysis
Section 306 IPC — Abetment of Suicide
Instigation requires evidence of urging, provoking, or encouraging suicide.
Mere words spoken in anger or frustration do not amount to instigation.
The suicide note and dying declaration clearly stated that Seema Devi alone was responsible.
The Court concluded that Ramesh Kumar did not abet her suicide, and the conviction under Section 306 was therefore set aside.
Section 498-A IPC — Cruelty
Cruelty includes acts likely to drive a woman to suicide or cause grave injury to life, limb, or health.
Evidence showed Ramesh Kumar pushed Seema out of the house and beat her, causing physical and mental suffering.
The Court upheld the conviction under Section 498-A, affirming that the acts amounted to cruelty.
Section 113-A Indian Evidence Act — Presumption
Section 113-A presumes abetment if a woman commits suicide within 7 years of marriage and has been subjected to cruelty.
The Court clarified that the presumption is rebuttable with evidence to the contrary.
In this case, since the evidence showed that Ramesh Kumar’s actions were not responsible for her suicide, the presumption did not apply.
4. Judgment / Outcome
Section 306 IPC (Abetment of Suicide): Conviction set aside.
Section 498-A IPC (Cruelty): Conviction upheld.
The Court emphasized the need for clear and convincing evidence for abetment of suicide and recognized the seriousness of cruelty in marriage.
5. Legal Significance
Clarification on 'Instigation': Mere words of anger or frustration cannot constitute abetment of suicide.
Cruelty under Section 498-A: Physical abuse and mental torture fall squarely within cruelty, and courts can uphold convictions with sufficient evidence.
Section 113-A Evidence Presumption: The presumption of abetment in cases of suicide within seven years of marriage is rebuttable; it does not automatically lead to conviction.
6. Related Case Laws
Shyama Devi vs State of UP: Courts emphasized that for Section 306, mere quarrels or disputes do not amount to instigation.
Rajesh Sharma vs State of UP (2017): Reinforced that Section 113-A presumption is rebuttable and must be considered with evidence.
Sanjay Kumar vs State of Bihar: Abetment of suicide requires active encouragement or instigation, not mere neglect or absence.
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