Back
SUPREME COURT OF INDIA
SANJAY KUMAR, ALOK ARADHE, JJ.
State Of Madhya Pradesh – Appellant
Versus
Janved Singh – Respondent
Criminal Appeal No. 460 of 2014
Decided on : 14-10-2025.
(A) Indian Penal Code, 1860 – Sections 302, 304B, 498A and 201 – Indian Evidence Act, 1872 – Section 106 – Dowry death, cruelty and disappearance of evidence – Appeal against acquittal – Circumstantial evidence – Conviction for murder can solely rest on circumstantial evidence if chain of circumstances is complete and consistent only with hypothesis of guilt of accused – Traditional rule relating to burden of proof of prosecution cannot be allowed to be wrapped in a pedantic coverage, offenders in serious offences would be major beneficiaries and society would be casualty – When accused offers a false explanation regarding cause of death which takes place within confines of his house, such falsity becomes additional link in chain of circumstances pointing to guilt of accused – Post-mortem report and evidence of Doctor showing that death of deceased was homicidal – Prosecution has established complete chain of circumstances – Findings recorded by High Court suffers from serious infirmity – Judgment of Trial Court restored. (Paras 12, 13, 14, 16, 19, 20, 21 and 22)
(B) Bharatiya Nagarik Suraksha Sanhita, 2023 – Section 419 – Appeal against acquittal – While dealing with appeal against acquittal reasons which weighed with Trial Court must be dealt with – Normal presumption of innocence gets reinforced with order of acquittal – If two views are possible from evidence on record, appellate court must be extremely slow in interfering with appeal against order of acquittal. (Para 15)
Facts of the case:
Law often steps into homes not to witness celebration, but to lift the veil from grief. Present appeal arises from such a home where warmth of a hearth turned into cold silence of death. State challenges the acquittal of two men, husband and father-in-law of young woman whose life ended in mysterious, yet telling circumstances.
Findings of Court:
High Court has not considered material evidence on record and has failed to take into account reasons which weighed with the Trial Court for convicting the accused Janved Singh.
Result : Appeal partly allowed.
JUDGMENT :
ALOK ARADHE, J.
The law often steps into homes not to witness celebration, but to lift the veil from grief. The present appeal arises from such a home where warmth of a hearth turned into cold silence of death. The State challenges the acquittal of two men, the husband and father-in-law of young woman whose life ended in mysterious, yet telling circumstances.
2. This appeal by the State is directed against judgment and order dated 06.04.2010 in Criminal Appeal No. 66 of 2000, whereby High Court of Madhya Pradesh, Bench at Gwalior, has set aside the conviction and sentence of both the respondents, recorded by Sessions Judge for offences under Sections 302, 304B, 498A and 201 of the Indian Penal Code, 1860, and has acquitted them.
PROSECUTION CASE
3. The deceased Smt. Pushpa was married to accused No.2, Mahesh. The marriage however was beset with discord. The deceased was subjected to harassment and cruelty at the hands of her husband (A-2) and father-in-law Janved Singh (A-1), on account of demand for dowry.
4. On 31st December, 1997, accused No.1 lodged a report at Police Station, Gormi stating that when he returned from the agricultural field, he found the deceased lying dead and she died due to electrocution while ironing the clothes. On the basis of said intimation, the Police registered Merg report (Ex.P-16) under Section 174 of the Code of Criminal Procedure, 1973. After the preliminary inquiry, the Police converted the Merg into a regular Criminal Case and registered Crime No. 9/1998 for offences under Sections 302, 498-A, 193 and 201 read with Section 34 of the Indian Penal Code, 1860 (for short “IPC”).
5. During the investigation, Police found discrepancies in the scene of occurrence and the condition of the body of the deceased. The post-mortem examination conducted by Dr. Devendra Khare, revealed that cause of death was asphyxia due to strangulation and burn marks on the body were post-mortem. On completion of the investigation, the Police filed chargesheet for offences under Sections 498-A, 304-B and in the alternative 302 read with Section 149 and Section 147 of the IPC against five accused persons namely, Janved Singh (father-in-law), Mahesh Singh (husband), Ramkali (mother-in-law), Sharda (sister-in-law), and Ahivaran Singh (brother-in-law) of the deceased.
TRIAL AND CONVICTION
6. The prosecution during the course of the Trial examined as many as 20 witnesses and produced documentary evidence namely, Exhibits P-1 to P-19. The parents of the deceased Pushpa and her uncle namely, Sobran Singh (PW-2), Ilaychi Bai (PW-19) and Ramesh (PW-4) were examined. Ramesh (PW-4), the maternal uncle of deceased, corroborated the statements of the parents of the deceased. The Investigating Officer (PW-18) described the details of the recovery of material evidence and sequence of investigation. The defence examined one witness Shri Ram Singh (DW-1), who in his statement stated that deceased Pushpa’s death was purely accidental which was caused by electric shock while she was ironing the clothes and the accused have been falsely implicated.
7. The Sessions Court vide judgment dated 11th of January, 2000, on the basis of appreciation of evidence on record, held that theory of electrocution was wholly fabricated and deceased Pushpa’s death was homicidal in nature. The court further held that Mahesh Singh, the husband, was guilty of offences under Sections 304-B and 498-A of the IPC. It was also held that Janved Singh, the father-in-law, actively participated in the murder, fabricated a false report and attempted to cause disappearance of evidence. Accordingly, he was convicted under Sections 302, 498-A and 201 of the IPC and they both were sentenced to undergo rigorous imprisonment for ten years and rigorous imprisonment for life, respectively. The remaining co-accused namely, Ramkali (mother-in-law), Sharda (sister-in-law) and Ahivaran Singh (brother-in-law) were acquitted.
HIGH COURT’S VIEW
8. On appeal by the accused persons, the H
The main legal point established in the judgment is the binding effect of the settlement between the parties, the waiver of the right to seek re-employment by the workmen, and the entitlement of the ....
A lockout is justified if it is declared in response to an illegal strike or a strike that is in breach of a settlement or award.
The combination of eyewitness testimonies, recovery of the weapon used, and forensic examination results can establish guilt in criminal cases, even based on circumstantial evidence.
The conviction of an accused person under Section 27(3) of the Arms Act is not permissible in law if the accused is also charged with committing murder under Section 302 of the Indian Penal Code.
The court can enhance compensation based on the deceased's income and family dependency, and adjust the multiplier used by the Tribunal if found unjustified.
An indispensable Tool for Legal Professionals, Endorsed by Various High Court and Judicial Officers
Please visit our Training & Support
Center or Contact Us for assistance
Scan Me!
India’s Legal research and Law Firm App, Download now!
For Daily Legal Updates, Join us on :
Back to top
