High Court of Jharkhand Dismisses Appeal – Conviction Upheld for Husband in Wife’s Murder Case; “Mere Suspicion Cannot Replace Proof”

Court’s Decision:

The High Court of Jharkhand upheld the conviction of the appellant for the murder of his wife, affirming the trial court’s decision under Section 302 of the IPC. The appellant was sentenced to life imprisonment and a fine of ₹20,000. The court rejected the appellant’s plea of alibi and found the chain of circumstantial evidence complete, pointing conclusively to his guilt. The court noted, “Mere suspicion, however strong, cannot replace proof,” and emphasized that the burden of explaining the circumstances under Section 106 of the Indian Evidence Act lay with the appellant.

Facts:

The case revolves around the alleged murder of the appellant’s wife. The prosecution’s case was that the victim was consistently tortured and assaulted by the appellant after their marriage in June 2011. On 27.07.2014, the victim’s brother visited her home and attempted to pacify the situation, only to learn the next morning that his sister had been killed. The appellant was found sitting beside the dead body when the victim’s family arrived.

The post-mortem report indicated death by strangulation with visible ligature marks, fractured hyoid bone, and blood-tinged secretions from the nose and mouth, which confirmed asphyxia. The incident was reported to the police, and a chargesheet under Section 302 of the IPC was filed against the appellant.

Issues:

1. Whether the prosecution established that the death was homicidal in nature.
2. Whether the circumstantial evidence was sufficient to prove the appellant’s guilt.
3. Whether the trial court erred in relying on the testimonies of close relatives.

Petitioner’s Arguments:

The appellant’s counsel argued that the trial court’s judgment was based on conjectures and surmises, without any corroborative evidence. There were contradictions in the witnesses’ statements, and none of the witnesses directly implicated the appellant. It was also argued that mere suspicion, especially in cases involving marital discord, cannot lead to a conviction. Further, the absence of eye-witnesses and reliance on circumstantial evidence made the conviction unsustainable.

Respondent’s Arguments:

The prosecution argued that there was overwhelming evidence of marital discord and repeated incidents of torture. The victim was last seen alive with the appellant inside the confines of their house, and the murder occurred within the four walls of the house. The appellant’s explanation of the death due to epileptic fits was contradicted by medical evidence. Thus, the chain of circumstantial evidence was complete, and the plea of alibi could not be sustained.

Analysis of the Law:

To prove a case under Section 302 of the IPC, the prosecution must establish that the death was homicidal. Here, the prosecution’s reliance on circumstantial evidence required proving a complete chain linking the appellant to the crime. The court reiterated the principle that strong suspicion is not a substitute for proof, and the prosecution must establish guilt beyond a reasonable doubt.

Precedent Analysis:

The court referred to the Supreme Court’s ruling in Gumansinh v. State of Gujarat, (2022) 15 SCC 767, wherein it was held that relatives of the deceased cannot be considered untrustworthy merely because of their relationship. The court noted, “Law does not disqualify relatives from being witnesses,” and emphasized that their testimonies hold weight, especially in cases involving domestic violence.

The court also cited Anees vs State Govt. of NCT, 2024 SCC OnLine SC 757, which highlighted that under Section 106 of the Evidence Act, the burden shifts to the accused when the crime takes place within the accused’s exclusive knowledge.

Court’s Reasoning:

The High Court found that the testimonies of the victim’s relatives were consistent and credible, and the defense could not show that they were untrustworthy. The medical evidence ruled out natural causes such as epileptic fits, as the fracture of the hyoid bone and the presence of ligature marks were conclusive of strangulation. The court noted that the appellant failed to provide a plausible explanation and instead put forth a misleading defense. The court also rejected the alibi, as there was no evidence to support that the appellant was not present at the scene.

The appellant’s false plea and the circumstantial evidence were sufficient to establish his guilt beyond reasonable doubt. The court held that in the absence of direct evidence, a strong chain of circumstances, when coupled with motive, is sufficient to sustain a conviction.

Conclusion:

The appeal was dismissed, and the conviction and sentence passed by the trial court were affirmed. The court concluded that the prosecution successfully proved the appellant’s guilt, and the appellant’s attempt to mislead the court only reinforced his culpability.

Implications:

The judgment reiterates the importance of circumstantial evidence in cases where direct evidence is absent, especially in domestic violence-related deaths. The ruling underscores that in cases of unexplained deaths within the confines of a home, the burden shifts to the accused to provide a satisfactory explanation. This judgment also highlights the legal principle that a strong chain of circumstantial evidence, combined with motive, can establish guilt beyond reasonable doubt.

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