The Supreme Court has upheld the conviction of a husband for the murder of his wife inside their matrimonial home, holding that the chain of circumstantial evidence was complete and consistent only with the hypothesis of guilt.
The bench of Justice Pankaj Mithal and Justice Prasanna B. Varale observed that medical evidence, suspicious circumstances surrounding the death, the accused’s conduct after the incident, and the failure to provide a satisfactory explanation together established the offence beyond reasonable doubt.
The judgment was delivered by a Bench comprising Justice Pankaj Mithal and Justice Prasanna B. Varale in the case concerning appellant Chetan Dashrath Gade, who had challenged his conviction under Sections 302 and 201 of the Indian Penal Code.
According to the facts of the case, Rupali married the appellant on 24 April 2012 and was living in her matrimonial house with her husband and in-laws. On 23 August 2015, her father received information that she had died. Initially, the family was informed that she had allegedly committed suicide by hanging. However, when her relatives reached the hospital, they noticed injury marks on her cheek and ligature marks on her neck, creating suspicion regarding the circumstances of her death.
The prosecution had alleged harassment and dowry-related demands, including demands for money for purchase of a vehicle. However, while the trial court ultimately acquitted the accused persons of charges under Sections 498A and 304B IPC due to insufficient proof regarding cruelty and dowry demands, it convicted the appellant and another accused on charges of murder based upon circumstantial evidence. The High Court later extended the benefit of doubt to one co-accused but maintained the conviction against the husband.
Before the Supreme Court, the appellant argued that there was no eyewitness to the occurrence, no established motive and no direct evidence showing any intention to commit murder. It was further contended that medical experts had expressed differing opinions regarding the cause of death and that a suicide note had been recovered indicating that nobody was responsible for Rupali’s death. The defence therefore claimed that the benefit of doubt should have gone to the accused.
The State, on the other hand, argued that the death had occurred inside the matrimonial home and that the accused carried a substantial burden to explain the circumstances. The prosecution also relied heavily on post-mortem findings showing fracture of the hyoid bone and trachea and evidence pointing toward death by strangulation rather than hanging.
The Supreme Court examined the medical evidence and attached significance to multiple circumstances that contradicted the theory of suicide. The Court particularly noted that the deceased’s left earring, right leg anklet and toe-rings were missing. According to the Court, if the death had resulted from hanging, disappearance of these ornaments was highly improbable. The Court observed that this circumstance strongly supported the prosecution’s allegation of strangulation.
The Bench also noted the existence of fresh injuries on Rupali’s cheek and relied upon post-mortem findings indicating anti-mortem injuries and signs of strangulation. The medical examination had revealed fracture of the hyoid bone and trachea and concluded that the probable cause of death was “asphyxia due to strangulation.”
The Court further scrutinised the conduct of the accused after the incident. It observed that although one doctor had already declared Rupali dead and advised taking her to a civil hospital, the accused subsequently took her body to another private hospital without any satisfactory explanation. The Court viewed this conduct as suspicious.
Importantly, the Supreme Court rejected the defence based on the alleged suicide note. It noted the trial court’s finding that the handwriting evidence suggested the note had been obtained forcibly prior to the incident and was projected as a false defence.
The Court also emphasized the role of Section 106 of the Indian Evidence Act, holding that since the death occurred in the matrimonial home under suspicious circumstances, the facts were within the special knowledge of the husband. His inability to provide a satisfactory explanation became an additional factor strengthening the prosecution’s case.
Reaffirming principles governing conviction based on circumstantial evidence, the Supreme Court concluded that the prosecution had successfully established a complete and unbroken chain of circumstances pointing only toward the guilt of the accused and inconsistent with any hypothesis of innocence. Consequently, the appeal was dismissed and the conviction and sentence under Sections 302 and 201 IPC were upheld.
Case Details
Case Title: Chetan Dashrath Gade Versus The State Of Maharashtra
Citation: JURISHOUR-1339-SC-2026
Case No.:CRIMINAL APPEAL NO. 1063/2021
Date: 21/05/2026
