Buddhadeb Saha & Ors. v. State of West Bengal — Post-mortem and viscera report gaps not fatal under the Section 304B dowry-death presumption

Part of the Forensic Docket on Legal Desire Forensics — a conviction confirmed through final appeal, kept here as a method-of-crime record.

The facts

The question before the Supreme Court was whether the High Court had erred in holding a husband and his in-laws guilty of offences under Sections 498A and 304B, read with Section 34, of the Penal Code.

The prosecution’s case was that the wife had died by consuming poison after being harassed for dowry.

Notably, the post-mortem report was silent as to the exact cause of death, and the viscera report was silent as to any trace of poison being found in it.

The Court considered the effect of these gaps on the prosecution’s case, and, weighing them against the rest of the evidentiary record, dismissed the accused’s appeal and affirmed the conviction.

Status: conviction upheld through final appeal.

Why this belongs in the Forensic Docket: An instructive case on the limits of forensic silence: a post-mortem and viscera report that fail to positively confirm the exact cause or agent of death do not automatically defeat a Section 304B dowry-death case built on the surrounding evidentiary record.

Case details

Read the full judgment (PDF), sourced from the Indian Supreme Court Judgments open dataset (AWS Open Data Registry, CC-BY-4.0).

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