Supreme Court Acquits Man in Wife’s Murder Case: “Prosecution Failed to Prove Guilt Beyond Reasonable Doubt, Circumstantial Evidence Must Form a Complete Chain”

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Court’s Decision

The Supreme Court of India set aside the conviction of the appellant, who had been found guilty of murdering his first wife by strangulation. The Court ruled that the prosecution had failed to establish the guilt of the accused beyond a reasonable doubt. It observed that the entire case was based on circumstantial evidence that did not meet the legal standards required for conviction.

The Court emphasized that the five essential principles of proving guilt through circumstantial evidence, laid down in Sharad Birdhichand Sarda v. State of Maharashtra (1984) 4 SCC 116, had not been met. Since the evidence did not exclude the possibility of the deceased dying a natural death, the benefit of doubt had to be given to the accused.

As a result, the Supreme Court acquitted the appellant and ordered his immediate release, noting that he had already served over ten years in jail.

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Facts

1. The appellant resided in a jhuggi (temporary dwelling) in Amritsar, Punjab, along with his first wife (deceased), his second wife, and two sons. They had lived together in this setup for over 10-12 years.
2. On the night of August 22, 2014, the deceased was allegedly strangulated by the appellant, with his second wife suspected to be an accomplice.
3. The brother of the deceased, Chaina Ram (PW-1), lodged a Zero FIR at Police Station Rajgarh, Rajasthan, stating that his sister had been murdered by her husband in connivance with his second wife.
4. The appellant transported the body in a truck from Punjab to Rajasthan, where the brother of the deceased lived.
5. The post-mortem report cited asphyxia due to hanging, with ligature marks around the neck. However, the doctor later admitted that these marks could have been due to tuberculosis or the long journey of the body.
6. The prosecution’s key witnesses—the brother (PW-1), sister (PW-2), and cousin (PW-3) of the deceased—turned hostile in court, contradicting their earlier statements.
7. The investigating officer recovered a rope allegedly used in the crime, but he admitted in cross-examination that similar ropes were commonly available in the market.
8. The appellant claimed in his Section 313 CrPC statement that his wife had died naturally due to tuberculosis, and this was never disproved by the prosecution.

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Issues Before the Court

1. Did the prosecution establish the appellant’s guilt beyond a reasonable doubt based on circumstantial evidence?
2. Was Section 106 of the Indian Evidence Act applicable in shifting the burden of proof onto the accused?
3. Did the courts below properly consider the alternative defense provided by the appellant?

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Petitioner’s (Appellant’s) Arguments

1. No Direct Evidence: The prosecution had no eyewitnesses to the crime and relied entirely on circumstantial evidence, which did not conclusively establish guilt.
2. Key Witnesses Turned Hostile: The main witnesses, including the deceased’s brother, sister, and cousin, retracted their previous statements in court, stating that the deceased died naturally due to illness.
3. Inconclusive Medical Evidence:
   • The post-mortem report stated “asphyxia due to hanging” but did not conclusively establish strangulation.
   • The doctor admitted during cross-examination that tuberculosis could also cause asphyxia, and ligature marks might have been caused by the transportation of the body.
4. Unreliable Recovery of Rope: The rope allegedly used in the crime was not conclusively linked to the incident, as similar ropes were commonly available in the market.
5. Failure to Disprove Alternative Explanation: The appellant, in his Section 313 CrPC statement, clearly stated that his wife had tuberculosis and was undergoing treatment, but the prosecution failed to disprove this claim.
6. Misuse of Section 106 of the Evidence Act: The prosecution wrongly shifted the burden of proof onto the accused, rather than proving the case beyond a reasonable doubt first.

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Respondent’s (State’s) Arguments

1. Last Seen Theory: The accused was the last person with the deceased, and it was his responsibility to explain her death.
2. Applicability of Section 106 of the Evidence Act: Since the incident occurred inside the appellant’s home (jhuggi), it was argued that he had a special burden to explain how the deceased died.
3. Post-Mortem Report Supports Murder Charge: The ligature marks on the deceased’s neck indicated strangulation, supporting the theory of homicide.
4. Transporting the Body was Suspicious: The appellant carried the body from Punjab to Rajasthan, which indicated an attempt to cover up the crime.

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Analysis of the Law

1. Circumstantial Evidence Must Meet Strict Standards

The Court relied on Sharad Birdhichand Sarda v. State of Maharashtra (1984) 4 SCC 116, which set five essential conditions for convicting an accused based on circumstantial evidence:

• The circumstances must be fully established.
• The evidence must point only to the guilt of the accused.
• The circumstances must be conclusive in nature.
• The evidence must exclude all other hypotheses except the accused’s guilt.
• The chain of evidence must be complete.

The Supreme Court found that the prosecution failed to meet these requirements, as there were multiple alternative explanations for the cause of death.

2. Section 106 of the Evidence Act Was Wrongly Applied

The State relied on Trimukh Maroti Kirkan v. State of Maharashtra (2006) 10 SCC 681, arguing that Section 106 placed a burden on the accused to explain how his wife died.

However, the Supreme Court referred to the recent case of Anees v. State Govt. of NCT (2024 SCC OnLine SC 757), which clarified that:

• The initial burden of proof is always on the prosecution.
• Section 106 cannot be used to compensate for weak prosecution evidence.

Since the prosecution failed to prove its case prima facie, Section 106 could not be invoked.

3. Section 313 CrPC Statement of the Accused Was Ignored

• The appellant clearly stated that his wife had tuberculosis and was under treatment.
• The prosecution never presented medical records to contradict this claim.
• Failure to disprove this explanation further weakened the prosecution’s case.

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Court’s Reasoning

1. The key prosecution witnesses turned hostile, and their testimony did not support the murder theory.
2. The post-mortem report was inconclusive, as the doctor admitted natural causes (tuberculosis) could have caused asphyxia.
3. Circumstantial evidence did not form a complete chain of guilt, as required by Sharad Birdhichand Sarda.
4. Section 106 of the Evidence Act was wrongly applied, shifting the burden to the accused when the prosecution had failed to prove guilt.
5. The accused’s Section 313 CrPC statement was ignored, despite presenting a valid alternative explanation.

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Conclusion

The Supreme Court quashed the appellant’s conviction, ruling that:

• The prosecution failed to prove guilt beyond a reasonable doubt.
• The evidence allowed for two interpretations, and the benefit of doubt had to be given to the accused.
• The appellant was ordered to be released immediately.

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Implications

1. Strengthens safeguards in circumstantial evidence cases.
2. Clarifies that Section 106 of the Evidence Act does not absolve prosecution of its burden of proof.
3. Reaffirms the importance of considering an accused’s Section 313 CrPC statement.
4. Upholds the principle that conviction must be based on strong, conclusive evidence.

This ruling reinforces fairness in criminal trials and ensures that accusations must be proven with certainty, not mere suspicion.

Also Read – Bombay High Court Modifies Murder Conviction to Culpable Homicide: “Incident Was a Sudden Quarrel Without Premeditation; Prosecution Failed to Prove Murder Beyond Reasonable Doubt”