Should an appellate court restore a conviction based on circumstantial evidence and false explanations despite a High Court’s acquittal?

Summary

What’s New / What Lawyers Should Note

• Reaffirms that a false explanation by an accused about cause of death constitutes an independent link in the chain of circumstances.
• Emphasises the duty of appellate courts to address each reason relied upon by the trial court before reversing an acquittal.
• Clarifies that medical evidence of homicidal death combined with demonstrable attempts to mislead investigation can justify restoration of conviction.
• Confirms that once prosecution proves circumstances pre-eminently within accused’s knowledge, Section 106 Evidence Act shifts burden to the accused to explain.

Summary of Legal Reasoning

1. Nature of Appeal
   • Appeal against acquittal: appellate court must deal with reasons of the trial court and exercise restraint.
2. Medical and Investigative Evidence
   • Post-mortem: ligature marks and post-mortem burns establish homicidal death.
   • Falsified electrocution theory: accused’s own FIR contradicted by medical evidence.
3. Chain of Circumstances
   • Unnatural death in accused’s house under his control.
   • Accused’s uncorroborated claim of absence from home.
   • Persistent dowry harassment testified by parents and uncle.
   • Deliberate lodging of false report to mislead police investigation.
4. Burden of Proof (Section 106 Evidence Act)
   • Prosecution proved facts within accused’s exclusive knowledge.
   • Accused failed to provide any independent evidence.
5. Conclusion
   • The only reasonable hypothesis is guilt; High Court’s interference was perverse.

Arguments by the Parties

Petitioner (State of Madhya Pradesh)

• High Court improperly reappreciated and discarded credible medical and testimonial evidence.
• Dowry demands and cruelty were established by PW-2, PW-19 and PW-4.
• Post-mortem proved homicidal death; electrocution theory was fabricated to mislead investigation.

Respondent (Janved Singh)

• No direct or circumstantial evidence linking him to the offence.
• Statements of close relatives were belated and inadmissible.
• Essential ingredient for Section 304-B IPC (death within seven years of marriage) was not proved.
• No evidence of his presence or overt act at the time of death; High Court’s acquittal should stand.

Factual Background

1. The deceased married Mahesh Singh, but faced alleged dowry harassment by her husband and father-in-law.
2. On 31st December 1997, the father-in-law reported her death as accidental electrocution.
3. Post-mortem contradicted this: death by strangulation with post-mortem burn marks.
4. Sessions Court convicted both; High Court reversed and acquitted them on reappraisal.
5. Supreme Court limited the appeal to the father-in-law, found a complete chain of circumstances and restored his conviction.

Statutory Analysis

• Section 106, Evidence Act, 1872: burden of proof remains on prosecution; shifts to accused for facts exclusively in his knowledge once prosecution discharges primary burden.
• Indian Penal Code Provisions: Sections 302 (murder), 304-B (dowry death), 498-A (cruelty), and 201 (causing disappearance of evidence) were central to conviction.

Alert Indicators

• ✓ Precedent Followed – Affirms established principles on circumstantial evidence and appellate restraint.