Judicial Analysis Court Copy Headnote Facts Arguments Court observation

2026 Supreme(SC) 795

SUPREME COURT OF INDIA
Dipankar Datta, Satish Chandra Sharma, JJ.
Piyush Shyamdasani – Appellant
Versus
State of Uttar Pradesh – Respondent
Criminal Appeal No(s). 3866 of 2025 with Criminal Appeal No(S). …..of 2026 [Arising out of SLP(Criminal) No. 12964 of 2025] Criminal Appeal No(S). ……of 2026 [Arising out of SLP(Criminal) No. 19093 of 2025], Criminal Appeal No(S). ….of 2026 [Arising out of SLP(Criminal) No. 2043 of 2026]
Decided On : 20-07-2026

Advocates appeared:
For the Appellant(s) : Mr. Prabhat Ranjan Raj, AOR Mr. Ankit Goel, AOR Mr. Shantanu Sagar, AOR Mr. Nikhil Sharma, Adv. Mr. Anil Kumar, Adv. Mr. Gunjesh Ranjan, Adv. Mr. Prakash Kumar Mangalam, Adv. Mr. Manoneet Dwivedi, Adv. Mr. Abhishek Kumar Gupta, Adv. Ms. Anshala Verma, Adv.
For the Respondent(s): Mr. Ashutosh Ghade, Adv. Mr. Ashutosh Ghade, AOR Ms. Saloni Meshram, Adv. Mr. Navin Pahwa, Sr. Adv. Mr. Mahesh Agarwal, Adv. Mr. Ankur Saigal, Adv. Mr. Gautam Khazanchi, Adv. Ms. Sanjivani Pattjoshi, Adv. Ms. Shivani Agarwal, Adv. Mr. E. C. Agrawala, AOR Mr. Ankit Goel, AOR Mr. Ashutosh Ghade, Adv. Mr. Ashutosh Ghade, AOR Ms. Saloni Meshram, Adv.

In cases based on circumstantial evidence, a conviction is sustainable if the prosecution establishes a complete, unbroken chain of evidence. Once the prosecution proves a strong nexus, the failure of the accused to explain incriminating facts within their personal knowledge justifies an adverse inference.

Headnote:(A) Indian Penal Code, 1860 - Sections 302, 364, 201, 203, 404 read with 120-B - Murder, abduction, destruction of evidence - Criminal Conspiracy - Conviction based on circumstantial evidence - Circumstances must form a complete chain unequivocally pointing towards the guilt of accused - Failure to explain incriminating circumstances exclusively within personal knowledge of accused leads to adverse inference. (Paras 13, 17, 18, 21)

(B) Evidence Act, 1872 - Section 27 - Discovery based on disclosure statement - Admissibility - Recoveries made at the instance of accused from exclusive knowledge, such as weapons and incriminating articles, are admissible and carry significant evidentiary value. (Paragraph 22)

(C) Appellate Jurisdiction - Scope and Ambit - Powers in appeal against conviction - Once a conviction is properly returned by trial and appellate courts, the presumption of innocence is displaced - Appellate court exercises power to reappreciate evidence to ensure findings are not perverse or against the record. (Paragraph 13)

Facts of the case:
The appellant husband conspired with others to murder his wife. After taking the deceased for dinner, he orchestrated a fake abduction and assault scenario to suggest outside involvement. Investigations revealed a pre-existing conspiracy evidenced by call records, constant communication between the accused, and their presence at the scene. The trial court convicted the accused based on these circumstances; the high court maintained the conviction for most, while acquitting one individual due to a lack of evidence linking her to the conspiracy.

Findings of Court:
The court found that the prosecution established a complete chain of circumstantial evidence. The husband provided no plausible explanation for his unnatural conduct, such as lack of injuries during a purported physical struggle, or his subsequent attempt to evade medical examination. Technical evidence regarding telephonic communications and location data confirmed the coordination among the conspirators. The acquittal of one accused was upheld as the evidence of her participation in the conspiracy was insufficient, despite evidence of a personal relationship.

Issues: Whether the conviction based on circumstantial evidence, particularly concerning the existence of a conspiracy and the application of criminal liability, was legally sustainable given the arguments regarding evidence and the role of the accused.

Ratio Decidendi: Where the prosecution establishes a chain of circumstances that leads to the unique conclusion of guilt, and the accused fails to provide any explanation for facts within their personal knowledge, an adverse inference is drawn. The chain of evidence was found complete, and the invocation of common intention was correctly applied as the act of murder involved coordinated participation, even if some conspirators were not physically present during the final act.

Result: Appeals of the convicts dismissed; conviction and sentences upheld; acquittal of the co-accused confirmed.

Table of Content
1. factual background of the marital homicide conspiracy case. (Para 1 , 2 , 3 , 4 , 5 , 6)
2. high court's previous evaluation of evidence and reasoning for acquittal. (Para 7 , 8)
3. arguments presented by appellants and the state concerning circumstantial evidence. (Para 9 , 10 , 11 , 12)
4. appreciating circumstantial evidence and behavioral conduct in criminal conviction. (Para 13 , 14 , 15 , 16 , 17 , 21 , 22)
5. evidentiary implications of failure to explain incriminating circumstances. (Para 18 , 19 , 20)
6. the limited role of motive in cases of strong circumstantial evidence. (Para 23 , 24 , 25)
7. distinction between section 34 ipc and section 141/142 (unlawful assembly). (Para 26)
8. insufficiency of evidence to establish conspiracy for acquittal of a2. (Para 27)
9. confirmation of convictions and order regarding remaining appellants. (Para 28 , 29)

JUDGMENT :

SATISH CHANDRA SHARMA, J.

1. Leave granted in SLP(Crl.) No. 12964 of 2025, SLP(Crl.) No. 19093 of 2025 and SLP (Crl.) No. 2043 of 2026.

2. Marriage is often dubbed as one of the most significant decisions in the life of a person. The consequences of a marital discord could be drastic and at times, even fatal. The present case depicts an extreme scenario wherein two lives have met an irreversible fate as a consequence of their marital discord. It is a case of a husband¹[Appellant – Piyush Shyamdasani], namely Piyush Shyamdasani, conspiring with some assailants (A3 to A6) to kill his wife, namely Jyoti Shyamdasani @Pooja Nagdev²[Originacl name before marriage.] and eventually succeeding in doing so. The case was registered as Crime No. 151/2014 P.S. Swaroop Nagar, Kanpur, Uttar Pradesh. After trial, the Trial Court convicted six accused persons for the commission of offences punishable under Sections 302, 364, 201, 203 and 404 read with 120-B of the Indian Penal Code, 1860³[Hereinafter referred as “IPC”]. The judgment of the Trial Court was assailed by the convicts before the High Court of Judicature at Allahabad by way of separate criminal appeals (lead appeal being Criminal Appeal No. 8254/2022). The appeals were disposed of together by the High Court vide common judgment⁴[2024:AHC:187614-DB] dated 29.11.2024. The judgment of the Trial Court was upheld by the High Court, with the exception of accused Manisha Makhija, originally convicted by the Trial Court under Sections 302/120-B and 201/120-B of IPC. She was acquitted by the High Court for want of sufficient evidence. The said judgment of the High Court is impugned before us herein.

3. Against the impugned judgment, four separate appeals have been filed. Three appeals have been filed by the appellants/convicts namely Piyush Shyamdasani/A1, Renu @Akhilesh Kanaujiya/A4 and Sonu Kashyap/A5, and fourth appeal has been preferred by the State of Uttar Pradesh taking exception to the acquittal of Manisha Makhija/A2. For convenience, the original ranks of the accused persons have been maintained in this judgment.

CASE OF THE PROSECUTION

4. As per the prosecution, A1 got married to the deceased on 28.11.2012. The marital relationship was strained and the deceased was at the receiving end of various instances of misbehavior and unpleasant encounters. Amongst other things, one of the issues was of a potential affair between A1 and A2, who was a neighbour of A1 and deceased. A1 used to remain out at night and used to have unusually long telephonic conversations with A2 and quite naturally, the deceased had a problem with the same and she had indicated it to her side of the family. Amidst all this, one fine day on 27.07.2014, A1 planned to take the deceased for dinner at Veranda Restaurant in Kanpur. This outing was planned after the conspiracy to kill the deceased was set to be executed.

5. A1 and deceased reached the restaurant at around 10:30 pm and the couple came out of the restaurant at 11:30 pm. Thereafter, they left together in A1’s Honda Accord car bearing number UP-78-BR-5009. There is a noteworthy diversion i

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2026 Supreme(SC) 795

Cases Referred (2)