Judicial Analysis Court Copy Headnote Facts Arguments Court observation

2024 Supreme(SC) 962

SUPREME COURT OF INDIA
BELA M. TRIVEDI, SATISH CHANDRA SHARMA, JJ.
Uma & Anr. – Appellants
VERSUS
The State Rep. By The Deputy Superintendent Of Police – Respondent
Criminal Appeal No. 757 of 2015 With Criminal Appeal No. 67 of 2016
Decided on : 22-10-2024

Advocates appeared:
For the Appellant(s) : Mr. T. R. B. Sivakumar, AOR Mr. Beno Bencigar, Adv. Mr. Kathirvelu.V, Sr. Adv. Mr. Vairawan A.s, AOR Mr. Rohan Singh, Adv. (arguing counsel) Mr. P. Soma Sundaram, AOR
For the Respondent(s): Mr. N.R.Elango, Sr. Adv. Mr. Sabarish Subramanian, AOR Mr. P. V. Yogeswaran, AOR

The judgment establishes that circumstantial evidence, when sufficiently strong and coherent, can lead to a conviction even in the absence of direct eyewitness testimony.

Headnote:
Criminal - Murder - IPC Sections 120B, 302 - The court interpreted the provisions of IPC regarding conspiracy and murder, establishing that the prosecution proved the guilt of the accused beyond reasonable doubt through circumstantial evidence and motive.
Fact of the Case:

The deceased, Rajalakshmi, was murdered by her husband and relatives shortly after marriage, with evidence suggesting a motive linked to an illicit relationship and harassment.
Finding of the Court:

The High Court found that the prosecution established a clear motive, presence of the accused at the crime scene, and medical evidence indicating homicide, reversing the trial court's acquittal.
Issues: Whether the prosecution proved the guilt of the accused beyond reasonable doubt and whether the trial court's acquittal was justified.
Ratio Decidendi: The court emphasized that circumstantial evidence must form a complete chain pointing to the guilt of the accused, and the burden of proof shifted to the accused under Section 106 of the Evidence Act.
Result: The appeals were dismissed, affirming the convictions of the accused for murder.

JUDGMENT

SATISH CHANDRA SHARMA, J.

Introduction

1. These appeal(s) assail the correctness of the Final Judgment/Order dated 04.03.2015 passed by the Hon’ble High Court of Madras at Madurai (the “High Court”) in Criminal Appeal (MD) No. 161 of 2011 titled State Vs Uma & Ors. whereby the judgement of acquittal dated 19.10.2010 passed by the Additional Sessions Judge, Fast Track Court No.1, Thoothukudi (the “Trial Court”) in Sessions Case No.300 of 2009, has been reversed and consequently, Appellant No.1/Accused No.1 has been convicted and sentenced to undergo imprisonment for life under Section 120B and 302 of the IPC together with a fine of Rs.10,000/- (Indian Rupees Ten Thousand); and Appellant No.2/Accused No.3 has been convicted and sentenced to undergo imprisonment for life under Section 120B read with 302 of the IPC together with a fine of Rs.10,000/- (Indian Rupees Ten Thousand). Pertinently, Ravi i.e., Accused No.2 was convicted and sentenced to undergo imprisonment for life under Section 120B and 302 of the IPC together with a fine of Rs.10,000/- (Indian Rupees Ten Thousand) (the “Impugned Order”). Ravi i.e., Accused No.2 has assailed the correctness of the Impugned Order before this Hon’ble Court by way of a separate criminal appeal i.e., Criminal Appeal No. 67 of 2016. As the appeal(s) arise out of a common judgement, they have been heard together; are being disposed of by this Judgement.

Case of the Prosecution

2. It is the case of the prosecution that on 23.08.2008, Ms. Rajalakshmi (the “Deceased”) was murdered by her husband, Mr. Ravi (Accused No.2) and her aunt & uncle i.e. Ms. Uma (Accused No.1) and Mr. Balasubramanian (Accused No.3).

3. The factual matrix reveals that the marriage between the deceased Rajalaksmi and the Accused No.2 had been solemnized at Arthi Thirumana Mandapam, Vilathikulam on 10.02.2008. At the time of marriage, 50 sovereign of gold jewels; and vessels and other items worth Rs.50,000/- (Indian Rupees Fifty Thousand) were given to the Husband and his family. As revealed by P.W.-1, Mr. Chandrakasan (PW-1), the adoptive father of the deceased in his examination, one week after the marriage, the Deceased had informed him, that Accused No.2 continuously harasses her & treated her like a servant. It was further stated that Accused No.2 used to consume alcohol, play cards, and also had an illegal illicit relationship with his aunt, i.e., Accused No.1. P.W.-1 in the Complaint (Exhibit P-1) and his examination as P.W.-1, stated that on one occasion Accused Nos. 1 and 2 along with Deceased came to his house, and Accused Nos. 1 and 2 slept together in a single bedsheet in the hall while the Deceased slept in the bedroom. It later came to his knowledge through the Deceased that this was not an usual practice at the Appellants’ home.

4. On 23.08.2008, one Arunachalam had informed P.W.-1 that the Deceased has consumed paint and had been taken to the local hospital. It was upon receiving the said information, P.W.-1 and his wife (P.W.-2) had come down to Government Hospital, Kovilpatti and found the dead body of the deceased in the mortuary. Subsequent thereto, P.W.-1 gave a written Complaint to the Sub Inspector of Police (P.W.-15) exhibited as Exhibit P-1, which was registered as Crime No. 183 of 2008 under Section 174 of the Code of Criminal Procedure, 1973. It is highlighted that none of the accused persons i.e., the Appellants, informed the P.W. 1 or the family of the deceased of her death.

5. The contents of the Complaint, reveal glaring details of the disturbing circumstances & troubles that the Deceased was being subjected to, by the Appellants at the time of her marriage and the said details, have been substantiated & corroborated by P.W.-1 in his cross-examination. The wife of P.W.-1 i.e., Ms. Sooriya Kalavathi has also adduced identical circumstances in her evidence, which affirm the allegations of the de-facto complainant. Notwithstanding thereto, such evidence needs to be tested on the anvil of consis