SONI DEVRAJBHAI BABUBHAI vs STATE OF GUJARAT .

The Supreme Court held that Section 304-B of the Indian Penal Code, inserted by Act 43 of 1986, creates a new offence of dowry death, which is not applicable to cases where the death occurred prior to its insertion. The Court clarified that Section 304-B is substantive law and not merely procedural, thus affirming the High Court's dismissal of the appellant's application to commit the case to the Court of Session. The ruling emphasized the prospective nature of the amendment and the protection under Article 20(1) against conviction for a new offence created after the commission of the act.