Supreme Court Affirms Conviction for Wife’s Murder: Homicidal Death Proven Beyond Doubt Through Medical Evidence, Illicit Relationship, and Chain of Circumstances

Court’s Decision:
The Supreme Court dismissed the appeal, upholding the High Court’s decision, which reversed the trial court’s acquittal. The appellants, accused of murdering the deceased, were found guilty beyond a reasonable doubt, with the court citing a clear motive, medical evidence, and circumstantial proof. The appellants were convicted under Section 120B and 302 of the IPC.

Facts:
The case revolves around the death of Rajalakshmi, who was found dead under suspicious circumstances six months after her marriage to Accused No.2, Ravi. She was allegedly subjected to harassment by her husband and his relatives, particularly her aunt and uncle (Accused Nos.1 and 3). The prosecution argued that the accused strangled the deceased and attempted to disguise the crime as a suicide by poisoning.

Medical evidence, including the postmortem report, revealed that the deceased suffered multiple ante-mortem injuries, including a fractured hyoid bone, indicating suffocation.

Issues:

1. Whether the High Court was correct in reversing the trial court’s acquittal and convicting the accused for murder.
2. Whether the prosecution successfully established a motive and proved the case beyond a reasonable doubt through circumstantial evidence.

Petitioner’s Arguments:
The appellants contended that the trial court’s judgment should not have been overturned as there was no direct evidence linking them to the crime. They argued that the prosecution’s case relied on circumstantial evidence and alleged motive, which was not adequately proven. The appellants also claimed they were not present at the scene of the crime and argued that the High Court failed to explain why the trial court’s view was not plausible.

Respondent’s Arguments:
The prosecution argued that the circumstantial evidence, combined with medical findings, clearly pointed to the guilt of the appellants. The prosecution emphasized the motive—an illicit relationship between the accused—which had strained the marriage and led to the murder. Furthermore, the prosecution pointed out inconsistencies in the appellants’ statements and the fact that they had not provided a credible explanation for the deceased’s injuries.

Analysis of the Law:
The court referred to the well-established legal principles governing cases based on circumstantial evidence. Citing the decision in Sharad Birdhichand Sarda v. State of Maharashtra, the court reaffirmed the five principles that must be satisfied to convict based on circumstantial evidence. It also emphasized the duty of the accused under Section 106 of the Indian Evidence Act to explain the circumstances leading to the death when it occurs in private or under suspicious circumstances, as in this case.

Precedent Analysis:
The court referred to Trimukh Maroti Kirkan v. State of Maharashtra, which holds that in cases where the accused resides with the deceased at the time of death, the burden shifts to the accused to explain how the death occurred. The court found that the appellants had failed to offer a plausible explanation, thus strengthening the prosecution’s case.

Court’s Reasoning:
The court noted that the medical evidence clearly indicated homicidal death by strangulation, supported by the broken hyoid bone and the absence of poison in the deceased’s system. The presence of the accused at the scene and their illicit relationship provided a clear motive. The court found that the trial court had failed to properly appreciate the medical evidence and circumstantial chain, which the High Court had correctly rectified.

Conclusion:
The Supreme Court held that the prosecution had successfully proven the case beyond reasonable doubt, establishing both motive and the chain of circumstances leading to the deceased’s death. The appeal was dismissed, and the conviction of the appellants was upheld.

Implications:
This judgment reinforces the legal standards for convicting based on circumstantial evidence and the responsibilities of the accused under Section 106 of the Evidence Act when a crime occurs within private domains. The case also highlights the role of motive and medical evidence in securing convictions in homicide cases.

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