Chhattisgarh High Court Upholds Life Imprisonment for Husband: “Burden of Explaining Wife’s Homicidal Death in Locked Room Lies on the Accused, Strengthening Conviction Under Section 302 IPC”

Court’s Decision

The Chhattisgarh High Court upheld the conviction of the appellant for murdering his wife under Section 302 of the Indian Penal Code (IPC). The appellant was sentenced to life imprisonment and a fine of ₹5,000, with an additional six months of rigorous imprisonment in default of payment. The court held that the appellant failed to provide a reasonable explanation regarding the circumstances of his wife’s death, which occurred within their home, as required under Section 106 of the Indian Evidence Act.

Facts

• The incident occurred on the night of September 26, 2022.
• The appellant’s nephew informed the complainant, Kamta Sahu (PW-1), that the appellant was assaulting his wife (the deceased) in a locked room. Family members attempted to intervene by breaking the door but were unsuccessful.
• The appellant eventually opened the door and fled the scene, leaving the deceased unconscious with visible injuries on her head and neck.
• The deceased was rushed to the District Hospital, where she was declared dead. The post-mortem report confirmed that the cause of death was asphyxia due to compression of the neck and chest, consistent with homicidal violence.
• A complaint was lodged, and the police investigation led to the appellant’s arrest. Evidence such as a spanner, nylon rope, and broken bangles was seized from the crime scene.

Issues

1. Was the death of the deceased homicidal in nature?
2. Could the appellant be held responsible for the murder based on circumstantial evidence?
3. Did the burden of proof under Section 106 of the Indian Evidence Act apply to the appellant in this case?

Petitioner’s Arguments

The appellant raised the following defenses:

1. The incident occurred during a sudden and grave provocation, and there was no intention to kill the deceased.
2. There were no eyewitnesses to the incident, and material prosecution witnesses turned hostile, making their testimony unreliable.
3. The trial court erred in convicting him solely on circumstantial evidence, without proving the motive for the crime.
4. Contradictions and omissions in the prosecution’s case cast doubt on the appellant’s guilt.
5. Section 106 of the Indian Evidence Act cannot be invoked unless the prosecution establishes a clear motive for the crime.

Respondent’s Arguments

The State, represented by the Panel Lawyer, contended:

1. The appellant and the deceased were the only individuals present in the house at the time of the incident, making Section 106 of the Evidence Act applicable.
2. The appellant failed to offer any plausible explanation for the death of his wife, either during the investigation or in his statement under Section 313 of the Criminal Procedure Code (CrPC).
3. Circumstantial evidence, supported by medical reports and witness statements, sufficiently established the appellant’s guilt.

Analysis of the Law

The court extensively analyzed the principles under Section 106 of the Indian Evidence Act, which places the burden on the accused to explain facts within his exclusive knowledge. It observed:

• When a crime occurs within the privacy of a house and the accused has exclusive knowledge of the circumstances, Section 106 shifts the burden of proof to the accused. This principle is particularly relevant in domestic homicide cases.
• The court referred to Trimukh Maroti Kirkan v. State of Maharashtra (2006), which emphasized that in cases where the offense occurs in a private space, the accused must provide a credible explanation to rebut the presumption of guilt.
• The court also cited Shambhu Nath Mehra v. State of Ajmer (1956), which clarified that Section 106 is not meant to relieve the prosecution of its duty to prove its case but applies to exceptional situations where the facts are exclusively within the accused’s knowledge.

Precedent Analysis

The court relied on the following landmark judgments:

1. Trimukh Maroti Kirkan v. State of Maharashtra (2006): Stated that in cases of domestic violence leading to death, the burden shifts to the accused to explain the circumstances of the crime.
2. Shambhu Nath Mehra v. State of Ajmer (1956): Highlighted that the burden on the prosecution can be alleviated in cases where facts are exclusively within the accused’s knowledge.
3. State of West Bengal v. Mir Mohammad Omar (2000): Discussed the doctrine of presumptions and its application in cases relying on circumstantial evidence.
4. Nagendra Sah v. State of Bihar (2021): Reiterated that the failure of the accused to discharge his burden under Section 106 provides an additional link in the chain of circumstantial evidence.

Court’s Reasoning

1. The court confirmed that the death was homicidal in nature based on the post-mortem report, which indicated asphyxia caused by compression of the neck and chest.
2. The appellant’s failure to provide any explanation under Section 313 of the CrPC strengthened the prosecution’s case.
3. Testimonies from family members, including the children of the deceased, established a history of domestic abuse and threats made by the appellant to kill the deceased.
4. The court concluded that the chain of circumstantial evidence was complete and pointed solely to the appellant as the perpetrator of the crime.

Conclusion

The High Court dismissed the appeal, upholding the conviction and sentence awarded by the trial court. The court directed the appellant to serve his sentence and informed him of his right to appeal to the Supreme Court with the assistance of legal aid.

Implications

This judgment reinforces the principle that in cases of domestic violence and homicide within a household, the accused has a heightened burden to explain the circumstances under which the crime occurred. It underscores the judiciary’s role in ensuring justice in cases involving vulnerable victims of domestic abuse.

Also Read – Bombay High Court Upholds Injunction Against Developer for Amending Sanctioned Plans Without Consent, Highlights Misrepresentation and Protection of Flat Purchasers’ Rights Under Maharashtra Ownership Flats Act, 1963.