Question

In Gurmeet Singh v. State of Punjab, 2021 SCC OnLine SC 403, a three-judge bench of the Supreme Court of India issued guidelines for trial in dowry death cases. The Bench comprised of:

• A. N.V. Ramana, Uday Umesh Lalit and A.M. Khanwilkar, JJ.
• B. N.V. Ramana, Sanjay Kishan Kaul and Surya Kant, JJ.
• C. N.V. Ramana, Surya Kant and Aniruddha Bose, JJ.
• D. N.V. Ramana, L. Nageswara Rao and Hemant Gupta, JJ.
• A. Section 2 of the Dowry Prohibition Act, 1961.
• B. Section 3 of the Dowry Prohibition Act, 1961.
• C. Section 498A of the Indian Penal Code, 1860.
• D. Section 304B of the Indian Penal Code, 1860.
• A. True.
• B. False.
• C. Neither true nor false as the application of the presumption is a matter of discretion of court.
• D. Neither true nor false as the application of the presumption depends on the facts of the case.
• A. The length of time between demand of dowry and death.
• B. The gravity of demand of dowry, including the existence of burns or injuries inflicted while making such demand.
• C. The length of marriage of the victim and the accused.
• D. The totality of circumstances of each case, without relying on any straight jacket formula.
• A. Is either homicidal or suicidal death.
• B. Is accidental death only.
• C. May be homicidal or suicidal or accidental death.
• D. Is suicidal death only.
• A. A criminal statute is to be interpreted strictly.
• B. Section 304-B of the Indian Penal Code, 1860 is to be read with the presumption under Section 113B of the Indian Evidence Act, 1872.
• C. Once these ingredients are satisfied, the rebuttable presumption of causality under Section 113-B of the Indian Evidence Act, 1872 operates against the accused.
• D. The legislative intent of Section 304-B of the Indian Penal Code, 1860 is to curb the social evil of bride burning and dowry demand.

Answer 1

The Correct Option is C

Step 1: Case background.
The case Gurmeet Singh v. State of Punjab dealt with dowry death under Section 304-B IPC and the presumption under Section 113-B of the Indian Evidence Act.
Step 2: Bench composition.
The judgment was delivered by a three-judge bench comprising the then Chief Justice of India N.V. Ramana, along with Justices Surya Kant and Aniruddha Bose.
Step 3: Conclusion.
Therefore, the correct combination is option (C). \[ \boxed{\text{C}} \]

Answer 2

Step 1: Dowry definition source.
The Dowry Prohibition Act, 1961 is the primary legislation dealing with the prohibition of dowry in India. v Step 2: Section reference.
Section 2 of this Act specifically defines the term “dowry” — any property or valuable security given or agreed to be given, directly or indirectly, in connection with marriage.
Step 3: Elimination.
Section 3 of the Act deals with the penalty for giving or taking dowry, Section 498A IPC addresses cruelty by husband or relatives, and Section 304B IPC defines dowry death but not “dowry” itself.
Step 4: Conclusion.
Thus, the definition is found in Section 2 of the Dowry Prohibition Act, 1961.
\[ \boxed{\text{A}} \]

Answer 3

Step 1: Nature of presumption under Section 113B IEA.
Section 113B states that when it is shown that “soon before her death” the woman was subjected to cruelty or harassment for dowry, the court shall presume that such person caused the dowry death.
Step 2: Mandatory presumption.
The term “shall presume” in the Evidence Act denotes a mandatory presumption, meaning the court must draw the presumption once foundational facts are established, though it remains rebuttable by the accused.
Step 3: Conclusion.
Given the statutory language, the statement that it is a “shall” presumption is correct. \[ \boxed{\text{A}} \]

Answer 4

Step 1: Elements of Section 304-B IPC.
To prove “dowry death,” the prosecution must show: (i) the woman’s death occurred otherwise than under normal circumstances within 7 years of marriage; (ii) soon before her death she was subjected to cruelty/harassment; (iii) such cruelty/harassment was for or in connection with dowry demand.
Step 2: Meaning of “soon before”.
The Supreme Court has consistently held that “soon before” does not mean ‘immediately before’. Courts must find a proximate and live link between the cruelty for dowry and the death; the interval is contextual, not fixed.
Step 3: How courts assess “soon before”.
Because proximity is a factual question, courts look at the entire mosaic of facts—nature and frequency of demands, pattern of cruelty, intervening events, and the timeline—to decide whether the link is live and proximate. There is no rigid formula or single-factor test.
Step 4: Eliminate the distractors.
- (A) Mere clock-time gap is not decisive; a short or long interval may still satisfy/fail the test depending on facts.
- (B) Gravity/injuries are relevant to cruelty but do not, by themselves, answer the proximity question.
- (C) Length of marriage is immaterial to “soon before”; it only matters that death occurred within 7 years.
\[ \boxed{\text{D}} \]

Answer 5

Step 1: Statutory phrase.
Section 304-B IPC uses the expression “otherwise than under normal circumstances,” purposely broad to capture any unnatural death.
Step 2: Judicial exposition.
Courts have clarified that this includes homicidal, suicidal, or accidental deaths—so long as they are not normal/natural. The nature (homicide/suicide/accident) does not limit Section 304-B; the key is the dowry-linked cruelty ‘soon before’ death.
Step 3: Apply to options.
- (A) & (D) improperly narrow the category to only some kinds of unnatural death.
- (B) restricts it to accidents alone—incorrect.
- (C) correctly states that any unnatural death type suffices.
\[ \boxed{\text{C}} \]

Answer 6

Step 1: Interpreting “soon before”.
The expression “soon before” in Section 304-B IPC has been judicially interpreted to mean a time frame that is proximate and connected to the death, but not necessarily immediate. This ensures that the legislative intent—to punish dowry-related deaths—is fulfilled without imposing an unrealistic requirement of instantaneous cruelty before death.
Step 2: Role of Section 113-B, Indian Evidence Act.
Section 304-B IPC must be read together with Section 113-B of the Indian Evidence Act, 1872, which creates a rebuttable presumption that if a woman dies in unnatural circumstances within 7 years of marriage and was subjected to dowry-related cruelty “soon before” her death, the husband or his relatives caused the dowry death.
Step 3: Why not “immediately before”.
If “soon before” were read as “immediately before,” many genuine dowry death cases would fail merely because there was a short gap between cruelty and death, even though the link was live and proximate. The presumption in Section 113-B is designed to operate in such cases, so the law avoids an overly strict reading.
Step 4: Elimination of options.
- (A) is incorrect because strict interpretation here would frustrate the protective purpose of the law.
- (C) describes the effect of satisfying ingredients, but not the reason for interpreting “soon before” less strictly.
- (D) is true about legislative intent but not the direct reason for avoiding the “immediately before” interpretation.
- (B) correctly explains the doctrinal basis—reading IPC Section 304-B with Evidence Act Section 113-B.
\[ \boxed{\text{B}} \]