Accused’s False Explanation Regarding Cause Of Death Which Took Place In His House Becomes Additional Link Pointing To His Guilt: Supreme Court

The Apex Court was considering an appeal filed by the State against the judgment of the Madhya Pradesh High Court setting aside the conviction and acquitting the husband and father-in-law of a young woman whose life ended in mysterious, yet telling circumstances. The accused respondents were booked in a case registered under Sections 302, 304B, 498A and 201 of the Indian Penal Code, 1860.

The Division Bench of Justice Sanjay Kumar and Justice Alok Aradhe stated, “It is well settled in law that when an accused offers a false explanation regarding the cause of death which takes place within the confines of his house, such falsity becomes an additional link in the chain of circumstances pointing to the guilt of the accused.”

AOR Sarad Kumar Singhania represented the Appellant, while AOR Anil Shrivastav represented the Respondent.

Factual Background

The deceased woman was married to the second accused, but the marriage was beset with discord. The deceased was subjected to harassment and cruelty at the hands of her husband and the father-in-law (first accused), on account of the demand for dowry. In the year 1997, the first accused lodged a report at the Police Station stating that when he returned from the agricultural field, he found the deceased lying dead, and she died due to electrocution while ironing clothes. After the preliminary inquiry, the Police converted the Merg into a regular Criminal Case and registered a criminal case for offences under Sections 302, 498-A, 193 and 201 read with Section 34 of the Indian Penal Code, 1860 (IPC).

The postmortem report revealed that the cause of death was asphyxia due to strangulation, and burn marks on the body were post-mortem. On completion of the investigation, the Police filed a chargesheet for the offences under Sections 498-A, 304-B and in the alternative 302 read with Section 149 and Section 147 of the IPC against five accused persons, i.e. the father-in-law, husband, mother-in-law, sister-in-law and brother-in-law of the deceased. The Sessions Court found the husband and the father-in-law guilty and acquitted the others. The High Court acquitted both the accused persons. The scope of the appeal before the Apex Court was confined only to the acquittal of the father-in-law of the deceased.

Reasoning

Explaining the law relating to appeal against acquittal, the Bench said, “It is equally well settled legal proposition that while dealing with an appeal against the acquittal, the reasons which weighed with the Trial Court must be dealt with. The normal presumption of innocence gets reinforced with an order of acquittal. If two views are possible from the evidence on record, the appellate court must be extremely slow in interfering with an appeal against an order of acquittal.”

Referring to the evidence adduced by the prosecution, the Bench noted that the same established the complete chain of circumstances, namely the fact that the unnatural death of the deceased was not accidental but homicidal as established from the medical evidence. The evidence also established that the death occurred inside the house occupied by the first accused, which was under his control.

The FIR lodged by the first accused himself established his presence in the house at the relevant time, and the version of the father-in-law that he had gone to the field was wholly unsubstantiated by any witness or independent corroboration. The evidence also established the deliberate lodging of a false report of electrocution and an attempt to mislead the investigation and the strained relations, as well as the persistent demands for dowry.

“Each link fits seamlessly with the next, forming a continuous chain which points unerringly to the guilt of accused No.1 and excludes all reasonable hypothesis of innocence. Once the aforesaid circumstances pointing out the guilt of the accused No.1 was proved, the burden was on the accused No.1 to explain the circumstances under which the deceased died in the house occupied by him. The accused No.1 has miserably failed to discharge the aforesaid burden”, it stated. As per the Bench, the prosecution had proved beyond a reasonable doubt that the first accused caused the death of the deceased by strangulation and attempted to mislead the investigation by fabricating a false story of electrocution.

Partly allowing the appeal, the Bench set aside the impugned judgment and ordered the accused father-in-law to be taken into custody forthwith to serve out the remainder of the sentence.

Cause Title: State of Madhya Pradesh v. Janved Singh (Neutral Citation: 2025 INSC 1229)

Appearance

Appellant: AOR Sarad Kumar Singhania, Advocates Anil Hooda, Rashmi Singhania

Respondent: AOR Anil Shrivastav

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