In the Supreme Court case State of U.P. Versus Ajmal Beg[1], the Court decided that Ajmal Beg and his mother, Jamila, were guilty under Sections 304-B IPC/80 BNS and 498-A IPC /85 BNS and Sections 3 and 4 of the Dowry Prohibition Act. Nasrin, the woman who died, had burn injuries within seven years of her marriage. Her parents and uncle told the Court that Ajmal and his family repeatedly asked for a colour television, a motorcycle and fifteen thousand rupees. They also said that Nasrin was treated badly just before she died. The High Court had said they were not guilty, but the Supreme Court disagreed. The Supreme Court said that even if some parts of what witnesses said do not match, it does not mean the whole case is wrong. The Court also said that since it was proven that Nasrin was treated cruelly for dowry just before she died, the accused were presumed to be guilty under Section 113-B IEA/118 BSA. Ajmal Beg was sentenced to life in prison. Jamila was found guilty but did not have to go to prison because of her old age. The Supreme Court restored the conviction of Ajmal Beg and Jamila. Ajmal Beg and Jamila were held responsible for Nasrin’s death. Ajmal Beg and his mother, Jamila, were found guilty in the case, and the Supreme Court restored their conviction.

RATIO DECIDENDI

  1. Proof of dowry demand, harassment, and reiteration of demand one day before death satisfies Section 304-B IPC/ 80BNS and triggers the presumption under Section 113-B IEA/ 118 BSA. The Court held that the consistent evidence regarding demand for a motorcycle, colour TV and Rs. 15,000, coupled with threats and harassment immediately before death, established all essentials of dowry death.

“Equally so, in no manner could it be disputed that the said demand had been reiterated just a day prior to the deceased passing away”

(Para 20, pg. 32–33)

  1. The presumption under Section 113-B IPC / 118 BSA is mandatory once foundational facts are proved and remains operative unless rebutted by the defence. Since the accused led no defence evidence, the presumption remained unrebutted.

“Here itself, it may then be noted that the presumption under Section 113-B / 118 came into effect as soon as it stood proved that the deceased had been subjected to cruelty soon before her death, and went unrebutted by the defence, since no evidence was led by them”

(Para 20, p. 33)

  1. Minor contradictions or omissions in witness testimony do not justify acquittal if the core prosecution story remains intact. The Court applied the principle that discrepancies must be weighed against the overall substratum of the case, not isolated mechanically.

    “but that is not to say that their evidence as to the salient features of the case after cautious scrutiny cannot be considered”[2]

(Paras 19, 19.1, pp. 31–32; Para 21, pp. 33–35)

  1. Dowry under the Dowry Prohibition Act includes demands made before, at, or after marriage; the High Court erred in treating post-marriage demands as legally suspect.[3]

“The upshot of the discussion made in the preceding paragraphs is that the High Court has erred in setting aside the judgment of conviction returned by the Additional District Judge, Bijnor, and acquitting Ajmal and Jamila in connection with the FIR bearing No. 94/2001 registered at P.S Kiratpur, under Sections 498- A IPC /85 BNS and 304-B IPC/ 80 BNS and Section 3/4 of the DPA, 1961”

(Para 23, pp. 37–38)

OBITER DICTA

1. Extensive socio-historical discussion on dowry as a cross-cultural evil and constitutional imperative. The Court traced the evolution of dowry, its impact across religions, and linked eradication of dowry to Articles 14, justice, liberty and fraternity. These observations were not necessary to decide guilt.

(Paras 3–9, pp. 4–9)

  • Observations on humanitarian sentencing for elderly convicts. While restoring Jamila’s conviction, the Court refrained from imprisonment because she was 94 years old and incarceration would be inhumane. This concerns sentencing discretion, not the rule determining liability.

(Para 24, pp. 38–39)

  • Directions for educational reform, appointment and strengthening of Dowry Prohibition Officers, training of police and judges, awareness workshops, and expeditious disposal of pending dowry cases. These prospective policy directions were issued to improve enforcement and are not the ratio governing conviction.

(Paras 25–27, pp. 39–45)

  • Statistical observations on dowry deaths and misuse concerns. The Court noted both under-enforcement and occasional misuse of dowry laws, but these remarks were contextual and not essential to the adjudication.

(Paras 25–26, pp. 41–43)

This article has been researched and prepared by Shruti Sahu, Legal Research Intern at LegalRath.

[1] State of U.P. Versus Ajmal Beg and another (2025 INSC 1435)

[2] Sohrab s/o Beli Nayata and Another v State of Madhya Pradesh (1972) 3 SCC 751.

[3] Dowry Prohibition Act 1961, s 2