Bombay High Court held that, Irrespective of when a demand was made, either during/before marriage or subsequent to marriage, section 4 offence is made out.
From Para 7,
Pandurang Shivram Kawathkar Vs State of Maharashtra on 5 February 2001
Having regard to the dominant object of the Act which is to stamp out the practice of demanding dowry in any shape or form either before or after the marriage. The entire definition of the word ‘dowry’ should not be imported into Section 4 and a liberal construction has to be given to the word ‘dowry’ used in Section 4 to mean that any property or valuable security which if consented to be given on the demand being made would become dowry within the meaning of Section 2 of the Act. The object of Section 4 is to discourage the very demand for property or valuable security as consideration for a marriage between the parties thereto. Section 4 prohibits the demand for ‘giving’ property or valuable security which demand, if satisfied, would constitute an offence under Section 3 read with Section 2 of the Act. There is no warrant for taking the view that the initial demand for giving of property or valuable security would not constitute an offence and that an offence would take place only when the demand was made again after the party on whom the demand was made agreed to comply with it.
Citations: [2001 CriLJ 2792]
Other Source links: