Supreme Court sets aside Allahabad High Court's judgement, restores judgement of conviction in dowry case by Additional District Judge, Bijnor

Dowry, legally defined under Section 2 of the Dowry Prevention Act, 1961, refers to “any property or valuable security given or agreed to be given directly or indirectly” by one party to a marriage to the other, or by the parents of either party, in connection with the marriage.

In State of Uttar Pradesh v. Ajmal Beg & Ors. (2025), Supreme Court's Division Bench of Justices Sanjay Karol and N.K. Singh delivered a 46-page long judgement dated December 15, 2025, wherein, it concluded:"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 and 304-B, IPC and Section 3/4 of the DPA, 1961. The State’s appeals, therefore, deserve to be allowed. The judgment of the Trial Court, insofar as it relates to the conviction of both Ajmal and Jamila, is restored.... " The judgement was authored by Justice Karol. 

It observed" 26. With an intent to further this change, we issue the following directions: -

(a) to ensure that the change brought in is able to make an impact on the efforts to eradicate this evil, it is to be ensured that the future generation, youngsters of today, are informed and made aware about this evil practice and the necessity to eschew it. As such, it is directed that States and even the Union Government consider changes as are necessary to the educational curricula across levels, reinforcing the constitutional position that parties to a marriage are equal to one another and one is not subservient to the other as is sought to be established by giving and taking of money and or articles at the time of marriage;

(b) The law provides for the appointment of Dowry Prohibition Officers in States. It is to be ensured that these officers are duly deputed, aware of their responsibilities and given the necessary wherewithal to carry out the duties entrusted to them. The contact details (name, official phone number and email ID) of such an officer designated to this position are disseminated adequately by the local authorities ensuring awareness of citizens of the area;

(c)the police officials, as also the judicial officers dealing with such cases, should periodically be given training, equipping them to fully appreciate the social and psychological implications which are often at the forefront of these cases. This would also ensure a sensitivity of the concerned officials towards genuine cases versus those which are frivolous and abusive of the process of law;

(d) it is not lost on us that the instant case began in 2001 and could only be concluded 24 years later by way of this judgment. It is but obvious that there would be many such similar cases. The High Courts are requested to take stock of the situation, ascertain the number of cases pending dealing with Section 304-B, 498-A from the earliest to the latest for expeditious disposal; and

(e) in furtherance of (a) above, we also recognize that many people today are/have been outside the education fold, and that it is equally, if not more so, important to reach them and make accessible and comprehensible, the relevant information regarding the act of giving or taking of dowry as also other acts sometimes associated therewith, other times independent thereof (mental and physical cruelty) is an offence in law. The District Administration along with the District Legal Services Authorities, by engaging and involving civil society groups and dedicated social activists, is requested to conduct workshops/awareness programs at regular intervals. This is to ensure change at the grassroot level."

These appeals were at the instance of the State of Uttar Pradesh, laying challenge to a judgment of the High Court in Criminal Appeal under Section 374 Cr.PC. Nos. 5109 of 2003 and 5110 of 2003, entering a finding of acquittal of the respondents herein, setting aside the judgment and order dated October 7, 2003, of conviction returned by the Additional Sessions Judge, Bijnor in Sessions Trial 573 and 574 of 2001 arising out of the First Information Report bearing No. 94/2001 registered at P.S Kiratpur, under Sections 498-A and 304-B, Indian Penal Code, 1860 and Section 3/4 of the Dowry Prohibition Act, 1961.

In this case, a young girl, barely of twenty, when she was sent away from the world of the living by way of a most heinous and painful death, met this unfortunate end simply because her parents did not have the material means and resources to satisfy the wants or the greed of her family by matrimony. A coloured television, a motorcycle and Rs. 15,000/- is all she was apparently worth of.

Justice Karol observed:"The eradication of dowry is an urgent constitutional and social necessity. .....Although the law sought to prohibit the practice, dowry has persisted in society, slipping through the statutory definition, cloaked as “gifts” and social expectations. This practice is, at the most basic level, at odds with the values enshrined in the Constitution, i.e., the constitutional ethos of justice, liberty, and fraternity, and more particularly, Article 14, which guarantees equality before the law and equal protection of the laws, a principle directly undermined by a system that treats women as a source of financial extraction and reinforces structural discrimination."

The judgement reads:"27. Let a copy of this judgment be circulated electronically to the Registrar General of the High Courts who are requested to place the same before the Learned Chief Justices and solicit directions in accordance with the above, and also, to the Chief Secretaries of all States for necessary follow up action."