Mere Suspicion Cannot Lead To A Finding Of Guilt: Supreme Court Acquits Man Accused Of Killing His Wife
The Supreme Court allowed a Criminal Appeal of the accused-husband against the High Court's Judgment which convicted him under Section 302 of the IPC.
The Supreme Court has acquitted a man who was accused of killing his wife, reiterating that mere suspicion cannot lead to a finding of guilt.
The Court was deciding a Criminal Appeal filed by the accused-husband against the Judgment of the High Court which convicted him under Section 302 of the Indian Penal Code, 1860 (IPC).
The two-Judge Bench comprising Justice Sudhanshu Dhulia and Justice K. Vinod Chandran observed, “A mere suspicion cannot lead to a finding of guilt, especially when there is not available a chain of circumstances, unequivocally pointing to the guilt of the accused in the alleged crime, as has been held in Sharad Birdhichand Sarda v. State of Maharashtra.”
The Bench took note of the fact that there was no allegation of any physical violence on the deceased-wife and there were no injuries found on the body, immediately before the incident, which could lead to such an allegation.
AOR Sameer Shrivastava represented the Appellant while AOR Apoorv Shukla represented the Respondents.
Facts of the Case
One day on returning from work, the Appellant-accused (husband) allegedly found his wife lying supine on the cot inside their house. He immediately informed his parents living nearby and the Police Station where it was recorded under Section 174 of the Criminal Procedure Code, 1973 (CrPC) as a sudden and unnatural death. No suspicion was raised by anyone regarding the death. A Complaint was lodged by the deceased’s father, an FIR was registered, and the three accused persons were arrested.
A charge was framed under Sections 498A and 306 read with Section 34 of the IPC. The Trial Court acquitted the accused finding the deceased to have committed suicide and held that there was no circumstance pointing to the guilt of the accused. However, on the grounds only of the ‘alibi’ put forth having been discredited and the admission of the deceased and the accused living together in the same house, the High Court convicted the Appellant under Section 302 of the IPC. It upheld the acquittal of the in-laws. Hence, the Appellant was before the Apex Court.
Reasoning
The Supreme Court in view of the facts and circumstances of the case, said, “The death; not unequivocally proved to be a murder, of a young woman, married for two years, led to the prosecution of her husband and in-laws.”
The Court noted that the alibi being a possible and probable explanation, the accused cannot be found to be in the teeth of Section 106 of the Indian Evidence Act, 1872 (IEA).
“We find that there was not enough material to upset the order of acquittal of the Trial Court, especially when there was also no evidence led regarding the death being a result of homicide”, it added.
The Court further observed that there is not a single circumstance pointing to the guilt of the accused, leave alone, a chain of circumstances fully establishing the guilt of the accused and excluding every possible hypothesis, except that of guilt.
“True, the young woman, who was married just two years back died, tragically, at the house of the husband. There is no evidence to show that the husband was available on the ill fated night when the death occurred. The husband–accused had a plausible explanation that he was on duty when the death of his wife occurred. It was the husband who first intimated the police about the sudden and unnatural death of his wife”, it also noted.
The Court said that the relatives of the deceased having come to the matrimonial house of the deceased on the very same day of the death, did not raise any suspicion as to the death being homicidal.
“Having found absolutely no circumstance leading to the guilt of the accused, we are unable to sustain the order of the High Court which we set aside and restore the order of acquittal of the Trial Court”, it concluded.
Accordingly, the Apex Court allowed the Appeal, set aside the High Court’s Order, restored the Trial Court’s Order, and acquitted the accused husband.
Cause Title- Jagdish Gond v. The State of Chhattisgarh and Ors. (Neutral Citation: 2025 INSC 460)
Appearance:
Appellant: AOR Sameer Shrivastava, Advocates Niteen Sinha, Yashika Varshney, Palak Mathur, and Sangeeta Verma.
Respondents: AOR Apoorv Shukla, Advocates Prabhleen A. Shukla, and Ayush Acharjee.
