SMT. SHANTI AND ANR. vs STATE OF HARYANA

The Supreme Court held that Sections 304-B and 498-A IPC are not mutually exclusive, clarifying that both provisions address distinct offenses with 'cruelty' being a common element. The Court affirmed the High Court's conviction under Section 304-B for dowry death, emphasizing that the absence of a conviction under Section 498-A does not negate the establishment of cruelty necessary for a dowry death. The Court ruled that a person acquitted under Section 304-B can still be convicted under Section 498-A if the evidence supports it, but separate sentences are not required for both offenses.