#Section 113-B Evidence Act

The Supreme Court upheld a husband's murder conviction in a dowry death case, ruling that his fabricated defence of epileptic seizure - contradicted by post-mortem evidence of throttling - completed the circumstantial chain under Section 106 Evidence Act and triggered the Section 113-B presumption. The decision reinforces that a false plea on facts within the accused's exclusive knowledge can supply the missing link in dowry death prosecutions.

Once the prosecution proves Section 304-B IPC ingredients, Section 113-B Evidence Act shifts the burden to the accused to disprove dowry death; the Jharkhand HC upheld the conviction as the accused failed to rebut.

The Orissa High Court acquitted a husband and mother-in-law, ruling that the statutory presumption under Section 113-B Evidence Act cannot be invoked without foundational proof of cruelty 'soon before death'. Unfulfilled dowry demands and suspicious cremation alone are insufficient to sustain a Section 304-B IPC conviction, raising the evidentiary bar for dowry death prosecutions.

The Allahabad High Court ruled that a conviction under Section 304-B IPC can rest solely on a trustworthy dying declaration, rejecting arguments of delayed FIR. The Court also held that life imprisonment is not mandatory and must be proportionate to the accused's culpability, commuting sentences to time served for the appellants.