The Supreme Court has quashed a dowry death case against a Chandrapur man whose wife, an Indian woman living with him in Toronto, died by jumping from the 22nd floor of their apartment. It has held that the case against him rested on vague allegations that did not connect any dowry demand with her death.
To prosecute for dowry death under Section 304B IPC, the prosecution must show, with some material, that the woman was subjected to cruelty or harassment for or in connection with a demand for dowry soon before her death, and the presumption under Section 113-B of the Evidence Act arises only after these ingredients are shown. Wedding and festival gifts to a couple are not dowry in the absence of a demand, and vague, general allegations of harassment, unsupported by specific instances, cannot sustain a case under Sections 498A, 323 or 504 IPC. Where the FIR, even taken at face value, does not disclose the ingredients, the High Court should quash it under Section 482 CrPC to prevent abuse of the process.
Piyush Narlawar married the deceased on 3 January 2021 and moved with her to Canada in February 2022. She died on 11 June 2023, leaving a handwritten note that said she felt “stupid and useless” for not finding a job and wished to donate her organs. A Canadian coroner’s report and the Toronto Police found that there were no signs of struggle or foul play, no prior police contact, and that the husband was not at home and could be seen on the video coming up the elevator about half an hour later. Her father filed an FIR in Satara, Aurangabad on 30 June 2023 under Sections 304B, 323, 498A and 504 read with Section 34 IPC and Sections 3 and 4 of the Dowry Prohibition Act, alleging demands for 15 tolas of gold before the wedding, a gold ring and bracelet at the first Diwali, three tolas of gold in 2022 and a transfer of Rs 1 lakh from the wife’s brother. The Bombay High Court quashed the case against the husband’s parents and sister but refused to do so for him. Justices B.V. Nagarathna and Manmohan allowed his appeal. They noted that for over two years there was “not even a whiff” of a dowry complaint, the FIR came only after the death, and the suicide note did not mention him or any dowry. They held that the gold given at the wedding to both the daughter and the groom, and the Diwali gifts, may have been customary presents out of love and affection, and in any case could not be linked to a suicide nearly a year later. The Rs 1 lakh was transferred around the time that he booked her flight to India and was one of many transactions in their accounts. Calling him “stupid” or “useless” could reflect his temperament but did not amount to cruelty or intimidation. The allegations of hurt and intimidation were “vague and omnibus”, with no specific instance. The court found that parts of Bhajan Lal‘s guidelines applied and said the case was a father’s search for “some semblance of reason” for his daughter’s death.
Note: The court did not decide that no dowry was ever demanded, but held that the material did not support a prosecution. The court did not separately consider the High Court’s finding in favour of the other family members, who were already discharged. The judgment is marked non-reportable.
Citation: Piyush S/o Deepak Narlawar v. State of Maharashtra & Others, Criminal Appeal arising out of SLP (Crl.) No. 12158 of 2025, Supreme Court (Justices B.V. Nagarathna and Manmohan), decided on 02.11.2026 | 2026 INSC 1183
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