Facts
The law doesn’t always knock on the door to share in joy. Sometimes, it enters quietly, solemnly drawn not by festivity but by the lingering shadows of loss. This is the story of such a home, once full of warmth, now haunted by silence. Pushpa was a young woman, newly married into a family in Gormi, Madhya Pradesh. Her husband, Mahesh, and her father-in-law, Janved Singh, were once her guardians and companions in this new chapter of life. But from the very start, things were far from peaceful. Beneath the surface of family life, there were cracks sharp, painful, and dangerous. Pushpa was allegedly tormented for dowry. The pressure, the cruelty, the emotional abuse became her daily burden. Her dreams, once full of hope, began to fade. Then came the final day 31st December 1997. While the world was preparing to welcome a new year, in one household, a tragedy was unfolding. That afternoon, Janved Singh walked into the local police station and reported a terrible accident. According to him, he had returned from the fields only to find Pushpa lying lifeless, a victim, he said, of a tragic electrocution while ironing clothes. The police registered a “Merg” (unnatural death) report under Section 174 of the CrPC. At first glance, it seemed like a household mishap. But something didn’t sit right. The police launched a preliminary inquiry, and as they pulled back the curtain, the scene began to shift. Investigators noted inconsistencies—things that didn’t quite add up. The condition of Pushpa’s body, the burn marks, the supposed cause of death—all raised red flags. A post-mortem was ordered. Dr. Devendra Khare, who conducted the examination, delivered a chilling conclusion: Pushpa had not died from electrocution. She had been strangled. The burn marks? They were inflicted after her death. With that, the veil was lifted. A criminal case was registered—Crime No. 9/1998—and the charges were far more serious now: murder (Section 302), dowry death (Section 304B), cruelty (Section 498A), destruction of evidence (Section 201), and conspiracy. Five members of the family were named as accused: Janved Singh (father-in-law), Mahesh Singh (husband), Ramkali (mother-in-law),Sharda (sister-in-law), Ahivaran Singh (brother-in-law). The trial began. The Sessions Judge convicted Janved and Mahesh, holding them responsible for Pushpa’s death. The court acknowledged the cruelty she had suffered, the motive linked to dowry, and the deliberate attempt to cover up the murder. But the story didn’t end there. The convicted men appealed. The case reached the Madhya Pradesh High Court in Gwalior, where the defense argued for their innocence. On 6th April 2010, the High Court overturned the convictions. The court found the evidence insufficient, the chain of events incomplete, and acquitted both Janved and Mahesh of all charges. Now, the State has appealed this acquittal.
Issues
Whether the High Court was justified in reversing the Trial Court’s conviction and acquitting Janved Singh (father-in-law) of the deceased
Whether the prosecution established beyond reasonable doubt that Janved Singh was guilty of murder, dowry death, cruelty, and causing disappearance of evidence
Whether the circumstantial evidence was sufficient to prove the accused’s guilt in the absence of direct evidence
Legal Provisions
Section 302 – Murder – Janved Singh (father-in-law) was convicted under this provision for causing the death of the deceased by strangulation, which constituted homicidal death.
Section 304B – Dowry Death – This provision was charged against the accused where the death of a woman occurs within seven years of marriage under circumstances connected to dowry demand or harassment
Section 498A – Cruelty by Husband or Relatives – The accused were charged for subjecting the deceased to harassment and cruelty on account of dowry demands.
Section 201 – Causing Disappearance of Evidence – Janved Singh was convicted for attempting to cause disappearance of evidence by fabricating a false report of electrocution and misleading the investigation.
Section 34 – Acts Done by Several Persons in Furtherance of Common Intention – Initially invoked during investigation along with Section 302.
Arguments
Appellant
The State argued that the High Court fundamentally erred in reappreciating the evidence and discarding the credible testimony of key witnesses, particularly the parents and uncle of the deceased (PW-2, PW-19, and PW-4). The State emphasized that the testimony of these witnesses established persistent harassment and cruelty inflicted on the deceased Pushpa by her husband and father-in-law in connection with dowry demands. The appellant asserted that evidence showed Pushpa was ill-treated and beaten up shortly before her death.The State pointed to the autopsy report, which clearly proved that Pushpa was first strangulated (indicating homicidal death) and then subjected to an electric current post-mortem to disguise the death as accidental electrocution. The State contended that the accused (Janved Singh) fabricated a false story of electrocution and attempted to mislead the investigation, as well as cause disappearance of evidence relating to the crime. The prosecution submitted that the chain of circumstances was complete and unbroken, and all pointed towards the guilt of Janved Singh.
Respondent
The respondent contended that there was neither direct nor circumstantial evidence linking him to the alleged crime, highlighting that the key prosecution witnesses were all related to the deceased and their statements were recorded after considerable delay, rendering their testimonies unreliable. He further argued that the prosecution failed to prove the date or year of marriage an essential element for a charge under Section 304-B IPC—and that there was no evidence to establish his presence at the time of the death or any specific overt act attributed to him. Based on these grounds, the respondent urged that the High Court’s order of acquittal required no interference.
Analysis
The Supreme Court’s analysis emphasized that the medical evidence, particularly the post-mortem findings, clearly established the death of the deceased as homicidal by strangulation, and not accidental electrocution as claimed by the accused. The chain of circumstances unnatural death inside the house controlled by the accused, his presence at the time of incident, fabrication of a false report, strained family relations, and persistent dowry demands was found to be complete and pointed unerringly to Janved Singh’s guilt, excluding any reasonable hypothesis of innocence. The Court criticized the High Court for overlooking crucial material evidence and held that the accused’s failure to offer a plausible explanation for the death in his house further strengthened the prosecution’s case, warranting restoration of the trial court’s conviction
Judgement
The Supreme Court set aside the acquittal of Janved Singh by the High Court, holding that the prosecution had proved beyond reasonable doubt that he caused the death of his daughter-in-law by strangulation and attempted to mislead the investigation by fabricating a false story of electrocution. The Court restored the conviction and sentence passed by the Trial Court against Janved Singh and ordered that he be taken into custody to serve the remainder of his sentence. Thus, the appeal was partly allowed, specifically as regards Janved Singh.
Conclusion
In conclusion, the Supreme Court found that the prosecution had proved beyond reasonable doubt that Janved Singh caused the death of the deceased by strangulation and then attempted to mislead the investigation by concocting a false story of electrocution. The High Court’s acquittal was set aside, and the judgment and sentence of the Trial Court were restored against Janved Singh, who was ordered to be taken into custody to serve the remainder of his sentence. The appeal was accordingly partly allowed
Click here to read more: STATE OF MADHYA PRADESH VERSUS JANVED SINGH
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WRITTEN BY S. KAVIYA SRI
