Strained Relationship & Alleged Drunkenness Not Sufficient To Presume Guilt: Madras High Court Acquits Husband Accused Of Murdering Wife
The Court held that in a case based on circumstantial evidence, mere suspicion arising from a strained marital relationship cannot substitute proof, and the prosecution must establish a complete chain of circumstances excluding every hypothesis other than guilt.
The Madras High Court, while acquitting a husband accused of murdering his wife, has held that merely because the accused and the deceased had a strained relationship, and the accused was alleged to be a drunkard, it cannot lead to a presumption that the accused alone committed the offence, in the absence of a complete chain of circumstances.
The Court was hearing a criminal appeal challenging the conviction of the appellant under Section 302 IPC by the Sessions Court.
A Division Bench of Justice N. Anand Venkatesh and Justice P. Dhanabal observed: “Just because the accused person and the deceased had a strained relationship and the accused person was a drunkard, that cannot lead to a presumption that it is only the accused person who could have committed the offence.”
Afvocate G. Karuppasamypandiyan appeared for the appellant, while A. Thiruvadi Kumar, Additional Public Prosecutor, appeared for the State.
Background
The prosecution’s case was that the appellant and the deceased were married and had children. Due to the appellant’s alleged addiction to alcohol and inability to work following an injury, frequent quarrels arose between the couple, leading to a strained relationship.
It was alleged that on the date of the incident, the appellant strangulated his wife using a towel inside the house and assaulted her with a kitchen tool, resulting in her death due to cardio-respiratory arrest caused by mechanical asphyxia.
The case was registered based on a complaint lodged by the brother of the deceased. During the investigation, material objects were recovered, and witnesses were examined. The trial court, relying on circumstantial evidence including alleged motive and recovery of material objects, convicted the appellant under Section 302 IPC.
The appellant challenged the conviction, contending that there was no direct evidence, the prosecution failed to establish the chain of circumstances, key witnesses were not examined, and the conviction was based on mere suspicion.
Court’s Observation
The Court noted at the outset that the case rested entirely on circumstantial evidence, and therefore the prosecution was required to establish a complete chain of circumstances leading only to the guilt of the accused.
The Court found serious gaps in the prosecution's case, particularly the failure to examine the most crucial witness, namely the minor son of the deceased and the accused, who was the first person to know about the incident. It was observed that this witness could have established key aspects such as the presence of the accused and the “last seen” circumstance. The Court held that “this is a very serious lapse on the part of the Investigation Officer.”
The Court emphasised that in cases based on circumstantial evidence, the last seen theory forms a vital link, and in the absence of such evidence, the chain of circumstances remains incomplete.
The Court further noted that no independent witness had spoken about the presence of the accused at the scene of the occurrence at the relevant time. In the absence of such evidence, the burden could not be shifted to the accused under Section 106 of the Evidence Act.
The Court reiterated the settled legal principle governing circumstantial evidence and observed: “in a case of circumstantial evidence, it is the prosecution which has to prove each circumstance that forms a chain so as to completely exclude every hypothesis other than the guilt of the accused.”
The Court also found that several key witnesses, including neighbours, had turned hostile, and the prosecution failed to establish the last seen theory or any other incriminating circumstance connecting the accused to the crime.
On the issue of motive, the Court held that a mere strained relationship or allegations of drunken behaviour cannot form the sole basis for conviction, particularly in the absence of supporting evidence.
The Court further observed that the trial court had erred in placing undue reliance on suspicion arising from the strained relationship and recovery of material objects, and reiterated the settled principle that “even a strong suspicion is not enough to convict a person.”
The Court emphasised that suspicion, however strong, cannot substitute proof beyond a reasonable doubt.
The Court also held that where two views are possible in a case based on circumstantial evidence, the view favourable to the accused must be adopted, thereby extending the benefit of doubt.
Upon a cumulative assessment, the Court concluded that the prosecution had failed to establish a complete and unbroken chain of circumstances, and that the conviction was unsustainable.
Conclusion
The Court set aside the judgment of conviction and sentence passed by the trial court and allowed the criminal appeal.
The appellant was acquitted of all charges and directed to be set at liberty.
Cause Title: M. Senthilmurugan v. Inspector of Police