No Dowry Harassment ‘Soon Before’ Death: Allahabad HC Acquits Man, Relatives 35 Years After Wife Found Dead In Well

The Allahabad High Court (Lucknow Bench) recently acquitted a Faizabad man and his relatives of dowry death charges, 35 years after his wife was found dead in a well, stating that the prosecution's case was riddled with contradictions and never proved she was harassed for dowry before she died.

The bench of Justice Manoj Bajaj set aside a trial court's 1996 conviction of Shiv Narain @ Surya Narain, Jai Narayan and Pateshwar under Sections 498-A, 304-B, 201 and 120-B of the Indian Penal Code [corresponding to Sections 86, 80, 238 and 61of the BNS, respectively). Other co-accused died while their appeals were pending.

The bride found dead in a well

Urmila, 21, married Shiv Narain in May 1987. On the night of September 19-20, 1991, she went missing from her matrimonial home in Faizabad's Khurdabad locality. Her body was recovered from a well near the house the next day.

Her father, Medhi Lal Maurya, filed a police complaint only on October 2, 1991, i.e. 12 days after the body was found, alleging that his daughter had been harassed for dowry and murdered by her husband and in-laws, who then dumped her body in the well to destroy evidence.

Police registered a case under Sections 498-A, 304-B, 201 and 120-B IPC. No charge of murder under Section 302 IPC was ever filed. A trial court convicted the accused in 1996 and sentenced them to up to seven years in prison.

Court flags inquest statement, 12-day delay in FIR

The high court found that at the inquest, held the same day the body was recovered, Medhi Lal and his relatives who signed the inquest report stated they believed Urmila had drowned. No allegation of murder or dowry harassment was raised at that point, court noted.

The formal complaint accusing the family of dowry harassment came 12 days later. Court held this delay was not adequately explained, rejecting the prosecution's claim that police had pressured the family to stay silent.

No dowry harassment proved "soon before" death

Section 304-B IPC treats a death as a "dowry death" only if a woman is shown to have faced dowry harassment "soon before" her death, a condition that also triggers a legal presumption of guilt against the accused under Section 113-B of the Indian Evidence Act.

Court found this was not established. The alleged dowry demand for a scooter was said to have been made once, in November 1987. It did not feature in the FIR or in statements to police during the investigation, and was raised for the first time when Urmila's parents testified in court years later, court noted.

Between that demand and her death in September 1991, Urmila lived in her matrimonial home continuously for over two-and-a-half years and was enrolled in a stitching and embroidery course at a local training institute, a fact her father admitted under cross-examination. Relatives who could have corroborated the harassment claim were not produced as witnesses, court observed.

No medical evidence of murder

The postmortem report showed a single head injury, which the doctor who conducted it said was consistent with an accidental fall inside the well against a tubewell pipe. Court noted there was no evidence to support the theory that Urmila had been murdered and her body dumped to destroy evidence.

It also held that the trial court had wrongly treated the case as one of murder despite no charge under Section 302 IPC ever being framed, calling this approach "erroneous in law and perverse."

Extending the benefit of the doubt to the accused, the high court set aside the 1996 conviction and sentence, acquitting Shiv Narain @ Surya Narain, Jai Narayan and Pateshwar of all charges, and ordered their bail and surety bonds discharged.

Case Title: Shiv Narain @ Surya Narain vs. State of U.P. and connected appeals

Judgment Date: August 21, 2026

Bench: Justice Manoj Bajaj