Circumstantial Evidence Sustains Murder Conviction

The Supreme Court dismissed the criminal appeal and upheld the conviction and sentence under Sections 302 and 201 read with Section 34 of the IPC. The appellant had been convicted by the Sessions Court, and the Bombay High Court had affirmed the finding of guilt under Section 302 IPC while also sustaining the related conviction under Section 201 IPC.

Facts

The deceased, Rupali, was married to the appellant in April 2012 and was living in the matrimonial home with her husband and in-laws. The prosecution case was that on 23 August 2015, the family was informed that she had died. Her parents later saw a fresh injury mark on her cheek and a ligature mark on her neck. The prosecution also relied on earlier allegations of harassment and demand for money and gold.

The defence argued that there was no eyewitness, no proved motive, and that the medical evidence was inconsistent. It also relied on an alleged suicide note said to have been written by the deceased.

Issue

The central question was whether the death was suicidal or homicidal, and whether the circumstantial evidence formed a complete chain sufficient to sustain conviction for murder.

Reasoning

The Court held that the prosecution had established a complete and unbroken chain of circumstances pointing only to the guilt of the appellant. It accepted the medical evidence that indicated strangulation, including the post-mortem findings of fracture of the larynx and trachea and asphyxia, and rejected the suggestion that the death was a simple case of hanging.

The Court also placed weight on the fact that the death occurred inside the matrimonial home. In such a situation, the appellant was expected to offer a plausible explanation. The Court found that he failed to discharge the burden under Section 106 of the Evidence Act.

The alleged suicide note did not persuade the Court to take a different view. On the overall evidence, the Court found no perversity or illegality in the concurrent findings of the courts below.

Holding

The appeal was dismissed. The conviction and sentence under Sections 302 and 201 IPC were upheld.

Practical takeaway

Where the death occurs in the matrimonial home and medical evidence supports strangulation, a court may sustain conviction on circumstantial evidence if the accused offers no credible explanation.