SUPREME COURT ACQUITS MAN IN MOTHER’S DEATH CASE, CITING POSSIBILITY OF SUICIDE:

The Supreme Court on Wednesday (October 8) acquitted a man who had been convicted for the alleged murder of his mother, after observing that the case was based entirely on circumstantial evidence and that the prosecution had failed to establish guilt beyond reasonable doubt. A bench comprising Justices K.V. Viswanathan and K. Vinod Chandran found that the prosecution could not even conclusively prove that the death of the deceased was homicidal in nature. The Court held that medical evidence suggested the possibility of suicide, as the deceased suffered from schizophrenia, a fact that remained unrefuted by the prosecution.

The case arose from an incident in Taloni village, Ambajogai, Maharashtra, in 2010. The police received an anonymous tip regarding a “doubtful death.” Upon arrival, they discovered a crowd preparing to hurriedly cremate the body of the deceased, Sunanda. When the police announced that the case was being treated as a murder, the gathered crowd dispersed. Following an investigation, Sunanda’s son, Nilesh, was accused of matricide. The prosecution claimed that the appellant, who resided with the deceased, had organized the cremation hastily, suggesting a motive under Section 8 of the Evidence Act. Based on this reasoning and other circumstantial elements, the trial court convicted Nilesh and sentenced him to life imprisonment. The Bombay High Court upheld this conviction, prompting the appellant to challenge the decision before the Supreme Court.

Reversing the concurrent findings of the lower courts, the Supreme Court held that the very foundation of the prosecution’s case was doubtful. Justice Viswanathan, writing for the bench, observed that there was serious uncertainty about whether the death was even a homicide. The post-mortem doctor had initially stated that the cause of death was “asphyxia due to strangulation,” but during cross-examination, he admitted that the absence of a ligature mark on the back of the neck could also indicate death by hanging. The doctor further clarified that in a typical case of strangulation, a ligature mark should appear all around the neck. Based on this testimony, the Court held that the medical evidence was ambiguous and did not conclusively establish homicide. The possibility of suicide, it said, could not be ruled out.

The Court also pointed out significant investigative lapses. It noted that there was a “mystery” surrounding the origin and development of the case. The police had failed to identify or question anyone from the crowd that had initially gathered for the cremation. Moreover, no evidence placed the appellant at the scene during the first attempted cremation. The Court found it troubling that the authorities made no effort to investigate who organized the funeral or why the cremation was being conducted in such haste.

The bench further observed that the medical evidence, including the testimony of Dr. Salunke (PW-6) and the post-mortem report, did not conclusively prove that the death was homicidal. The alleged recoveries in the case were found to be unreliable, and the prosecution’s claimed motive was unsupported by evidence. The Court concluded that both the trial court and the High Court had erred in convicting the appellant on such weak and inconclusive evidence.

Holding that the prosecution had failed to discharge its burden and that a conviction could not rest on suspicion or conjecture, the Supreme Court allowed the appeal. The conviction and life sentence of the appellant were accordingly set aside, with the Court emphasizing that in cases based solely on circumstantial evidence, the chain of circumstances must be complete and consistent only with guilt. Since that threshold was not met in this case, the appellant was entitled to an acquittal.