SC Upholds Husband’s Conviction in Matrimonial Home Murder Based on Circumstantial Evidence

The Supreme Court affirmed the conviction of a husband for the murder of his wife within their matrimonial home, ruling that the failure to explain suspicious injuries and the absence of jewellery established an unbroken chain of guilt.

A bench comprising Justice Pankaj Mithal and Justice Prasanna B. Varale adjudicated upon the appeal challenging the concurrent findings of the High Court and the Trial Court. The Court scrutinized whether the appellant was rightly convicted under Section 302 of the Indian Penal Code, 1860 based on circumstantial evidence in a case where the defense alleged suicide but medical evidence suggested homicidal strangulation.

Medical Evidence and Suspicious Circumstances

The Court noted that the deceased died an unnatural death in her matrimonial home. While the defense argued suicide, the prosecution pointed toward strangulation, supported by medical testimony and the physical state of the body. Significant importance was placed on the fact that the victim's earrings, anklets, and toe rings were missing, which the courts below found to be a strong indicator of a struggle or foul play rather than suicide.

The Role of Section 106 of the Evidence Act

The bench emphasized that since the death occurred within the privacy of the matrimonial home, a heavy burden lay on the husband to explain the circumstances. The Court, in its reasoning, observed: "Section 106 of the Evidence Act will apply to those cases where the prosecution has succeeded in establishing the facts from which a reasonable inference can be drawn regarding the existence of certain other facts which are within the special knowledge of the accused. When the accused fails to offer proper explanation about the existence of said other facts, the court can always draw an appropriate inference."

The Five Principles of Circumstantial Evidence

In evaluating the evidence, the Court relied on the 'Panchsheel' principles established in Sharad Birdhichand Sarda V. State of Maharashtra ( "(1984) 4 SCC 116": 1984 CaseBase(SC) 194). It held that the prosecution successfully established a complete chain of events, including the conduct of the appellant in taking the body to multiple hospitals and the fabrication of a suicide note. Referring to Mekala Sivaiah V. State Of Andhra Pradesh, the bench reiterated that while Article 136 of the Constitution of India, 1950 provides wide powers, interference with concurrent findings is only warranted in cases of manifest illegality or grave miscarriage of justice.

On the issue of motive, the Court cited Mulakh Raj and Others v. Satish Kumar and Others ( "(1992) 3 SCC 43": 1992 CaseBase(SC) 436), noting that while motive is significant in circumstantial cases, its absence is not fatal when facts clearly point toward guilt. The Court also referred to Nagendra Sah v. State of Bihar to justify the inference drawn from the appellant's failure to discharge the burden under Section 106 of the Indian Evidence Act, 1872.

Background:

The case originated from the death of Rupali, who married the appellant in 2012. In August 2015, the appellant informed the deceased's family that she had committed suicide by hanging. However, the father of the deceased (P.W.1) noticed fresh injuries and missing jewelry, leading to an FIR. The Trial Court convicted the appellant and his brother for murder, though the High Court later acquitted the brother while maintaining the appellant's conviction. The Supreme Court concluded that the medical evidence of asphyxia due to strangulation and the fracture of the hyoid bone, coupled with the appellant's lack of explanation, left no room for the hypothesis of innocence.

Case Details:
Case No.: CRIMINAL APPEAL NO. 1063/2021
NeutralCitation: 2026 INSC 522
Case Title: CHETAN DASHRATH GADE v. THE STATE OF MAHARASHTRA

Source: 2026 CaseBase(SC) 447