“Motive Is Irrelevant”: Supreme Court Upholds Conviction Of Husband Accused Of Murdering Wife By Strangulating Her

The Court observed that the accused had failed to furnish any plausible explanation regarding the suspicious death of his wife inside the matrimonial home and had failed to discharge the burden cast upon him under Section 106 of the Indian Evidence Act.

The Court was hearing a criminal appeal filed by the husband challenging the judgment of the Bombay High Court affirming his conviction under Sections 302 and 201 of the Indian Penal Code for the murder of his wife. The High Court had upheld the finding that the death was homicidal and not suicidal.

A Bench comprising Justice Pankaj Mithal and Justice Prasanna B. Varale observed: “The medical evidence, the attending circumstances surrounding the death of the deceased within the matrimonial home, the conduct of the appellant subsequent to the incident, the false defence sought to be projected through the alleged suicide note, and the failure of the appellant to furnish any plausible explanation in discharge of the burden cast upon him under Section 106 of the Indian Evidence Act, cumulatively form a chain so complete as to leave no reasonable ground for doubt.”

The Bench further observed: “in the cases of circumstantial evidence when the chain of circumstances have been adequately proved to link to the culpability of the accused, motive is irrelevant.”

Senior Advocate Ardhendumauli Kumar Prasad appeared for the appellant. Advocate Aditya Krishna appeared for the State of Maharashtra.

Background

The deceased married the appellant in April 2012 and resided in her matrimonial home with her husband, in-laws, and younger brother-in-law.

According to the prosecution, on the date of the incident, the father of the deceased had informed her father-in-law that he intended to bring her to her parental home on the occasion of Raksha Bandhan. Later in the day, information was received that the deceased had allegedly committed suicide.

The father of the deceased and other relatives rushed to the matrimonial house and thereafter to the hospital, where they found the deceased dead. The prosecution alleged that there were fresh injury marks on her cheek, ligature marks on her neck, and certain ornaments usually worn by her, including earrings, anklets and toe rings, were missing.

An FIR was thereafter lodged alleging that the deceased had been subjected to ill-treatment and harassment at her matrimonial home and had been murdered by the accused persons.

After the trial, the Sessions Court convicted the husband and another accused under Sections 302 and 201 read with Section 34 IPC, while acquitting them of offences under Sections 498A and 304B IPC. Subsequently, the Bombay High Court acquitted the co-accused but upheld the conviction of the husband for murder under Section 302 IPC and for destruction of evidence under Section 201 IPC.

Aggrieved thereby, the husband approached the Supreme Court.

Court’s Observation

The Supreme Court noted at the outset that the case rested entirely on circumstantial evidence; therefore, the principles laid down in Sharad Birdhichand Sarda v. State of Maharashtra (1984) governed the adjudication.

The Court reproduced the settled “five golden principles” governing circumstantial evidence, including the requirement that the chain of circumstances must be complete and inconsistent with any hypothesis of innocence.

The Bench observed that the death of the deceased inside the matrimonial home under unnatural circumstances was undisputed. The central issue was whether the death was suicidal or homicidal.

The Court undertook an extensive examination of the medical evidence and noted that the post-mortem report disclosed multiple ligature marks around the neck, fracture of the hyoid bone and trachea, congestion of lungs and the cause of death as “asphyxia due to strangulation.”

The Court also took note of the fresh injury mark found on the cheek of the deceased and the missing ornaments from her body. The Bench observed that the disappearance of earrings, anklets and toe rings was a strong circumstance inconsistent with suicide by hanging and indicative of physical struggle and strangulation.

The Court further found it significant that after one doctor declared the deceased dead and advised the accused persons to take the body to a civil hospital, the accused instead took her to another private hospital without any satisfactory explanation.

Rejecting the defence theory of suicide, the Court observed: “Though an attempt was made to submit that the allegation of strangulation is unsustainable and the strangulation itself is doubtful, the evidence referred to above clearly suggest that it was not the case of an act of suicide, particularly, in view of the injury marks found on the body of Rupali.”

The Bench also examined the alleged suicide note relied upon by the defence. The Court noted that although the handwriting expert opined that the writing was that of the deceased, the Trial Court had found that the chit had been forcibly obtained before the strangulation.

The Court observed: “The Trial Court on appreciation of the evidence particularly, the handwriting expert’s opinion found that the so-called chit had got written by the accused forcibly prior to the strangulation.”

The Supreme Court further emphasised that the accused failed to furnish any explanation regarding the suspicious death of his wife inside the matrimonial home, despite the facts being especially within his knowledge.

Relying upon Nagendra Sah v. State of Bihar (2021), the Court reiterated that where the prosecution establishes a chain of incriminating circumstances, failure of the accused to discharge the burden under Section 106 of the Indian Evidence Act becomes an additional link in the chain of circumstances.

The Court also rejected the argument that the absence of motive weakened the prosecution's case. Referring to Mulakh Raj v. Satish Kumar (1992), the Court reiterated that in cases resting on circumstantial evidence, the absence of proof of motive is not fatal where the chain of circumstances is otherwise complete.

Conclusion

The Supreme Court held that the prosecution had successfully established a complete and unbroken chain of circumstances proving that the death of the deceased was homicidal and that the appellant alone was responsible for the offence.

Accordingly, the Court dismissed the appeal and upheld the conviction and sentence imposed upon the appellant under Sections 302 and 201 IPC.

The Court, however, observed that the appellant would be at liberty to apply for premature release in accordance with the applicable State policy.

Cause Title: Chetan Dashrath Gade v. State of Maharashtra (Neutral Citation: 2026 INSC 522)

Appearances

Appellant: Senior Advocate Ardhendumauli Kumar Prasad with Siddharth S. Chapalgaonkar, Sneha Sanjay Botwe, Siddhanth Kumar and Akash Tripathi

Respondents: Aditya Krishna, Siddharth Dharmadhikari, Aaditya Aniruddha Pande, Shrirang B. Varma and Bharat Bagla for the Respondent-State.

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