The Supreme Court has upheld the life sentence awarded to a husband for murdering his wife within nine months of their marriage, holding that his failure to explain her homicidal death inside the matrimonial home, coupled with a medically disproved claim of an epileptic seizure, completed the chain of circumstantial evidence against him.
A Bench of Justice Sandeep Mehta and Justice Devendra Kumar Upadhyaya also sustained the convictions for cruelty and dowry death under Sections 498-A and 304-B read with Section 34 of the Indian Penal Code.
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The Court found consistent and corroborated evidence of persistent harassment over demands for cash, consumer goods and land. It held that the accused had failed to rebut the statutory presumption under Section 113-B of the Indian Evidence Act, 1872.
The case arose from the death of Vimalbai, who married Ramkishan Digambar Jadhav on May 12, 1995. She died at her matrimonial home on February 1, 1996.
According to the prosecution, she faced physical and mental cruelty shortly after marriage over demands for a television set, a tape deck, a plot in the MIDC area and ₹50,000 in cash to help her husband secure employment.
Her brother Narayan, the first informant, testified that she repeatedly complained about harassment during visits to her parental home. During a visit for Sankrant in January 1996, she complained of beatings and starvation.
His testimony also described an incident in which she was tied with a rope and lowered into a well, accompanied by a threat to kill her if the demands were not fulfilled.
In the early hours of February 1, 1996, the husband informed her brother that she was experiencing convulsions and was being taken to Naigaon for treatment. Her relatives subsequently found her lying lifeless in a bullock cart while travelling towards Naigaon. Doctors at the hospital declared her brought dead.
Before the brother lodged his complaint, the husband submitted an application to Naigaon Police Station claiming that his wife had suddenly experienced giddiness and locked jaws during sexual intercourse and had died.
The police initially recorded an entry in the Accidental Death Register and commenced an inquiry. However, the post-mortem examination identified the cause of death as “asphyxia due to throttling.”
Following investigation, six family members faced trial. A charge of dowry death under Section 304-B read with Section 34 IPC was subsequently added to the charges of cruelty and murder.
On September 21, 1998, the trial court convicted the husband, his father Digambar and his brother Venkat of cruelty and dowry death.
Each received one year’s rigorous imprisonment and a ₹500 fine under Section 498-A IPC, and seven years’ rigorous imprisonment under Section 304-B IPC. The substantive sentences were directed to run concurrently.
All six accused were acquitted of murder, while three female relatives were acquitted of all charges.
The convicted accused challenged their convictions, and the State appealed against the murder acquittals.
The High Court dismissed the convicts’ appeal but partly allowed the State’s appeal. It convicted the husband under Section 302 IPC and sentenced him to life imprisonment with a ₹5,000 fine, while maintaining the murder acquittals of the other accused.
The husband approached the Supreme Court separately from his father and brother. The father died during the proceedings, and the appeal stood abated insofar as he was concerned.
The appellants argued that the prosecution had failed to establish a complete and unbroken chain of circumstances pointing conclusively towards guilt.
The husband maintained that his wife’s death was accidental and resulted from an epileptic seizure during sexual intercourse.
On behalf of the other appellants, it was argued that they had been implicated because of their family relationship, without specific acts of dowry harassment being established against them. They also sought acquittal on parity with the three female relatives who had been acquitted.
The State relied on the medical findings, the circumstances of the death in the husband’s exclusive company and the evidence of continuing dowry harassment.
The Supreme Court found that the medical evidence firmly established homicidal death.
The post-mortem findings included haemorrhage over the laryngeal area, bruising over the thyroid cartilages and a fracture of part of the hyoid bone. The doctor expressly attributed the death to throttling.
The medical witness rejected the suggestion that an epileptic fit could have caused the internal neck injuries. There was also no lock-jaw or displacement of the tongue supporting the husband’s account.
The Bench therefore accepted the findings that the explanation of an epileptic seizure was false and concocted.
The Supreme Court attached significance to the husband’s own account placing him in his wife’s exclusive company when she died inside the matrimonial home.
Applying Section 106 of the Evidence Act, the Bench held that he was required to provide a cogent, credible and satisfactory explanation of circumstances especially within his knowledge. Instead, he advanced an account contradicted by the medical evidence.
The Court relied on Trimukh Maroti Kirkan v. State of Maharashtra, (2006) 10 SCC 681, concerning offences committed in the privacy of a house.
The precedent recognises that the initial burden remains on the prosecution, while Section 106 imposes a corresponding burden on persons possessing special knowledge of the occurrence to explain it.
On the evidence in this case, the husband’s failure to provide a plausible explanation, together with his false defence, supplied an additional incriminating link completing the circumstantial chain. The Bench held that the murder charge was proved beyond reasonable doubt.
The Court separately examined the convictions for cruelty and dowry death.
It noted that the death occurred within approximately nine months of marriage, well within the seven-year period prescribed under Section 304-B IPC.
The Bench found clear, consistent and mutually corroborative evidence of physical cruelty, mental torture and starvation linked to unlawful dowry demands.
The brother’s testimony received support from the marriage mediator, the deceased’s father and two independent neighbours of her parental home.
Their evidence established continuing harassment over demands for ₹50,000, a television, a tape deck and transfer of a plot in the MIDC area at village Ghungrala.
The Court held that the accused had failed to rebut the statutory presumption under Section 113-B of the Evidence Act and that the convictions recorded by the courts below were justified.
Finding no reason to interfere with the High Court’s judgment, the Supreme Court dismissed the surviving appeals as devoid of merit.
It cancelled the bail bonds and directed the surviving appellants to surrender before the trial court within four weeks of the judgment to serve the remaining portions of their sentences.
If they failed to surrender, the trial court was directed to take necessary steps, including issuing non-bailable warrants, to secure their arrest and custody.
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