BENCH: Justice B.R. Gavai, Justice Augustine George Masih and Justice K. Vinod Chandran
FACTS:
The case involves the tragic death of a woman allegedly due to dowry-related harassment and other domestic issues. The deceased was married to Accused No. 3, Umesh Chandra. On the morning of July 14, 1981, at around 6:00 AM, two individuals, Nand Kishore and Ram Prakash, both residents of village Rasoolpur, informed the deceased's uncle (PW-1) that she had died due to burn injuries. Upon reaching the accused’s house, the complainant and others found the deceased’s body placed on a cot, completely burnt from head to toe. The prosecution alleged that she had been subjected to ill-treatment due to non-fulfillment of dowry demands. Another motive attributed to the accused was that the deceased had not given birth to a child even after three years of marriage. Following the oral complaint by PW-1, a First Information Report (FIR) was registered under Sections 302/149 and 147 of the Indian Penal Code (IPC). After completing the investigation, a charge sheet was filed against six accused persons, and the case was committed to the Sessions Court, as it was exclusively triable by that forum. On December 8, 1983, the Special Judge (E.C. Act)/Additional Sessions Judge, Farrukhabad convicted all six accused under Section 302 read with Section 149 and Section 147 of the IPC. They were sentenced to life imprisonment for murder and one year of rigorous imprisonment for rioting, with both sentences running concurrently. Aggrieved by this decision, the accused filed a Criminal Appeal (No. 3036 of 1983) before the High Court of Judicature at Allahabad, challenging the trial court's ruling. However, on October 29, 2021, the Division Bench of the High Court dismissed the appeal, upholding the conviction and sentence. Subsequently, the appellants, who are original accused Nos. 1 and 4, have now approached the Supreme Court seeking relief.
ISSUES:
The main issue in the case is whether the accused are guilty beyond all reasonable doubt. The judgment passed by the Trial Court and the High Court was based on circumstantial evidence alone. The Apex Court has to determine whether these circumstantial evidence proves the guilt of the accused beyond reasonable doubt.
JUDGEMENT WITH REASONING:
After careful consideration of the facts and evidence, the Court has concluded that the conviction of the appellants is not legally sustainable. Both the High Court's judgment and order, as well as the Trial Court's ruling, suffer from legal infirmities and cannot be upheld. Accordingly, the appeal is allowed, and the impugned judgments of both the High Court and the Trial Court are quashed and set aside. The appellants are acquitted of all charges for which they were convicted. The Court further directs that the appellants be released immediately, provided they are not required to be detained in connection with any other case.
The Court's decision to overturn the conviction of the appellants was based on multiple legal and evidentiary shortcomings in the case. The prosecution primarily relied on the testimony of PW-1 and PW-2, the uncle and father of the deceased, respectively. While an independent witness, PW-3 (Raja Ram), was presented to support the claim that a commotion occurred in the accused’s house, both the Trial Court and the High Court deemed him a chance witness whose testimony lacked credibility and was therefore discarded.
The case occurred before Section 304-B of the IPC (dealing with dowry deaths) was introduced. As a result, the prosecution was required to establish the case strictly under Section 302 IPC (murder). The Court emphasized that for a conviction under Section 302 IPC, the prosecution must prove beyond reasonable doubt that the appellants were responsible for committing the crime. Although Section 106 of the Indian Evidence Act, 1872 places a burden on the accused to explain certain facts within their knowledge, this burden only arises after the prosecution has first established its case. In this instance, the prosecution was required to prove that the deceased was in the exclusive company of the appellants before her death. This would have been a different matter had the deceased been living alone with her husband at the time of death, as seen in the precedent set by Trimukh Maroti Kirkan v. State of Maharashtra. However, in the present case, around twelve family members were residing together, making it necessary for the prosecution to specify which accused individuals were present with the deceased before her death. Instead, the prosecution indiscriminately proceeded against all male family members and the mother-in-law, while excluding the wives of the other brothers of the accused.
The case rested solely on circumstantial evidence, requiring the prosecution to establish a complete chain of events leading to the appellants' guilt, as outlined in Sharad Birdhichand Sarda v. State of Maharashtra. However, the Court found that such a chain of circumstances was absent, failing to prove beyond reasonable doubt that only the appellants could have committed the crime. Furthermore, while dowry-related harassment was cited as a possible motive, the testimony of PW-2 (Hari Narain, the deceased’s father) contradicted this claim. His statements indicated that relations between both families were cordial, and he admitted that no complaints had ever been made regarding dowry-related ill-treatment. Additionally, the deceased was an educated woman, yet no letters or written complaints from her regarding dowry demands were presented in evidence.
The Court also criticized the High Court’s flawed approach, noting that it had wrongly relied on "plausibility" and "possibility" rather than the standard of proof beyond reasonable doubt. A conviction cannot be based on suspicion, no matter how strong, as reaffirmed in Sharad Birdhichand Sarda. Ultimately, given the prosecution’s failure to establish guilt beyond reasonable doubt, the Court held that the conviction of the appellants was legally unsustainable. Consequently, it quashed and set aside the judgments of both the Trial Court and the High Court, acquitted the appellants of all charges, and ordered their immediate release, provided they were not required in any other case.
ANALYSIS:
The Supreme Court’s ruling highlights the failure of the prosecution to establish guilt beyond reasonable doubt. Since the case relied entirely on circumstantial evidence, the prosecution needed to prove that the appellants were in exclusive proximity to the deceased before her death. However, with twelve family members in the household, the prosecution indiscriminately charged male members while excluding others, weakening its case.
The alleged motive—dowry harassment and childlessness—was also unsubstantiated. PW-2 (the deceased’s father) admitted that family relations were cordial, and there was no prior complaint or written evidence of dowry-related mistreatment. The Court reaffirmed that suspicion cannot replace proof, as established in Sharad Birdhichand Sarda v. State of Maharashtra.
The High Court’s reliance on plausibility rather than proof was a serious legal flaw. Criminal convictions must be based on certainty, not speculation. Given the lack of direct evidence and an unbroken chain of events, the Supreme Court rightly quashed the convictions, ensuring justice by preventing wrongful punishment based on weak evidence.
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