Homicidal death and unexplained injuries sustain conviction

The Supreme Court dismissed the criminal appeal and affirmed the conviction under Sections 302 and 498A IPC. The appellant had been sentenced to life imprisonment for murder and three years’ rigorous imprisonment for cruelty, and the High Court had already confirmed that result.

The prosecution case arose from the death of Soma Acharjee, the appellant’s wife, within about fifteen months of marriage. The FIR alleged dowry harassment and repeated intervention by village elders and family members. Though the family was initially told that she had died by suicide, the trial court framed charges under Sections 498A and 302 IPC, and the matter proceeded to trial.

The central issue before the Supreme Court was whether the death was suicidal, as claimed by the defence, or homicidal. The Court accepted the medical evidence of PW-13, the doctor who conducted the post-mortem. The report recorded injuries on the chest, jaw and occipital region, a depressed fracture of the scalp, and the absence of a typical ligature mark. The doctor opined that the deceased died of head injury caused by a blunt weapon like a hammer and was then put on hanging, describing it as a case of homicidal hanging.

The Court found that the post-mortem findings were consistent with that opinion. It noted the absence of signs ordinarily associated with a typical hanging death, including congestion in the conjunctiva, eyelids, face, nose, oropharynx, laryngopharynx and tongue, as well as the absence of tongue protrusion, vaginal discharge and fecal matter in the anus. On that material, the Court held that the deceased had not died by suicide.

The appellant’s defence was also weakened by his failure to offer any plausible explanation under Section 313 CrPC for the injuries or the circumstances in which the body was found. The Court observed that he was present when the body was discovered and had told the complainant that the deceased had committed suicide, but he did not discharge the burden of explaining the injuries or the death. The Court held that the defence version stood belied by the medical evidence.

The appeal was dismissed. The Court also directed that steps be taken to trace the absconding appellant and take him into custody.

Practical takeaway: In a murder trial, strong post-mortem evidence and an accused’s failure to explain the death can decisively sustain conviction.