1. A bride suffered an unnatural, homicidal death within one year of marriage amid allegations of cruelty, harassment, and unlawful dowry demands by her husband and in-laws. (Para 8 , 9 , 10 , 11 )
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2026 Supreme(SC) 1324
SUPREME COURT OF INDIA
SANDEEP MEHTA, DEVENDRA KUMAR UPADHYAYA, JJ.
Ramkishan Digambar Jadhav – Appellant
Versus
The State of Maharashtra – Respondent
Criminal Appeal No(s). 1849 of 2013 With Criminal Appeal No(s). 962 of 2014
Decided On : 02-11-2026
Important Points
IMPORTANT POINTCruelty and dowry death – Statutory burden rests heavily upon husband to offer a cogent, credible, and satisfactory explanation regarding circumstances culminating into unnatural death of his wife in her matrimonial home.
Subject
Criminal Law - Dowry Death and Murder
Act Referred
Headnote
Indian Penal Code, 1860 – Sections 498A and 304B read with Section 34 – Indian Evidence Act, 1872 – Sections 106 and 113-B – Cruelty and dowry death – Common intention – Conviction and sentence – Deceased met with unnatural death in her matrimonial home, within nine months of marriage – Explicit opinion was given by Doctor that cause of death was asphyxia due to throttling and internal neck injuries could not be caused by epileptic fit – Defence theory of death as a result of epileptic fit suffered during sexual act was found to be false and concocted by both Trial Court and High Court – Statutory burden rested heavily upon appellant-husband, who was in exclusive company and holding custody of his wife in privacy of the matrimonial home when she met with unnatural death, to offer a cogent, credible, and satisfactory explanation regarding circumstances culminating into her death – Instead of discharging this statutory burden, appellant set up a demonstrably false and concocted defence, which provides an additional incriminating link that completes chain of circumstantial evidence, and thereby establishing his guilt for offence of murder punishable under Section 302 of IPC – There is clear, consistent, and mutually corroborative evidence establishing that deceased was subjected to persistent physical cruelty, mental torture and even starvation at her matrimonial home over unlawful demands for dowry – Prosecution has duly proved essential ingredients of offences punishable under Section 498-A and Section 304-B read with Section 34 of IPC against appellants – Accused-appellants failed to rebut statutory presumption under Section 113-B of Evidence Act and were rightly convicted by Courts below. (Paras 34, 35, 36, 38, 39, 40, 41, 43, 44 and 45)
Facts of the case:
By impugned judgment, High Court dismissed Criminal Appeal No. 311 of 1998 preferred by appellants, Ramkishan Digambar Jadhav (accused No. 1), Digambar Narba Jadhav (accused No. 2), and Venkat (accused No. 5), thereby affirming their conviction and sentence for offences punishable under Sections 498-A and 304 B read with Section 34 of Indian Penal Code, 1860.
Findings of Court:
As a consequence of dismissal of appeals, bail bonds executed by them stand cancelled, and they are directed to surrender before Trial Court concerned within a period of four weeks from today to serve out remaining period of their sentences, failing which Trial Court shall take all necessary steps, including issuance of non-bailable warrants, to secure their arrest and take them into custody.
Issues: Whether the failure of the husband to provide a credible explanation under Section 106 of the Evidence Act, combined with the evidence of dowry harassment, justified the convictions under Sections 302, 304-B, and 498-A of the IPC.
Ratio Decidendi: An unnatural death occurring in the privacy of a matrimonial home invokes Section 106 of the Evidence Act, placing a burden on the husband to explain the circumstances of death. The introduction of a demonstrably false defense provides an additional incriminating link that completes the chain of circumstantial evidence for murder. Additionally, proof of cruelty soon before death within seven years of marriage triggers the statutory presumption of dowry death under Section 113-B of the Evidence Act.
Result: Appeals dismissed.
Legal Category Hierarchy
Advocates appeared:
For the Appellant(s) : Mr. Shivaji M. Jadhav- 1117, AOR Mr. Aditya S. Jadhav, Adv. Mr. Brij Kishor Sah, Adv. Ms. Apurva, Adv. Mr. Vignesh Singh, Adv. Ms. Shivali Chaudhary, Adv. Mr. Amit Kumar Gupta, Adv. Mr. Dere Kishor Shankar, Adv.
For the Respondent(s): Mr. Varad Kilor, Adv. Mr. Siddharth Dharmadhikari, Adv. Mr. Aaditya Aniruddha Pande- 3259, AOR Mr. Shrirang B. Varma, Adv.
For the Appellant(s) : Mr. Shivaji M. Jadhav- 1117, AOR Mr. Aditya S. Jadhav, Adv. Mr. Brij Kishor Sah, Adv. Ms. Apurva, Adv. Mr. Vignesh Singh, Adv. Ms. Shivali Chaudhary, Adv. Mr. Amit Kumar Gupta, Adv. Mr. Dere Kishor Shankar, Adv.
For the Respondent(s): Mr. Varad Kilor, Adv. Mr. Siddharth Dharmadhikari, Adv. Mr. Aaditya Aniruddha Pande- 3259, AOR Mr. Shrirang B. Varma, Adv.
Table of Contents
2. Defence argued circumstantial evidence is insufficient and pointed to accidental death; the prosecution contended the burden of proof shifted to the accused under Section 106, Evidence Act. (Para 19 , 20 , 21 , 22 , 25 , 26 , 28 )
3. The Court observed the accused failed to explain the death occurring in the privacy of the marital home, and medical evidence established death by strangulation, disproving the accidental death claim. (Para 34 , 35 , 37 , 38 , 40 , 43 , 44 )
4. When an offence occurs inside a private house, Section 106 of the Evidence Act shifts the burden onto the inmates to provide a cogent explanation of the circumstances. (Para 39 )
5. The court dismissed the appeals, confirming the conviction for cruelty, dowry death, and murder, and ordered the appellants to surrender to the trial court. (Para 45 , 46 , 47 )
6. What is the scope of Section 106 of the Evidence Act in cases involving death inside a private residence?
Section 106 creates a burden on the inmates of a house to explain the circumstances of a death happening in privacy, as these facts are within their special knowledge. Failure to provide a plausible explanation enables the court to draw incriminating inferences. (Para 38 , 39 , 40 )
7. Does a demonstrably false defence in a circumstantial evidence case impact the prosecution's claim?
Yes. When an accused provides a false or concocted narrative to explain how a victim died in their exclusive custody, it acts as an additional incriminating link that completes the chain of circumstantial evidence against the accused. (Para 36 , 40 )
8. What is required to prove an offence under Section 304-B of the Indian Penal Code?
The prosecution must establish that the death was unnatural, occurred within seven years of marriage, and was preceded by evidence of persistent cruelty or harassment by the husband or relatives in connection with unlawful dowry demands. (Para 42 , 43 , 44 )
JUDGMENT :
Mehta, J.
1. Heard.
2. These connected criminal appeals are filed by the appellants assailing the common judgment dated 3rd July, 2013 passed by the High Court of Bombay at Aurangabad1[Hereinafter, referred to as “the High Court”] in Criminal Appeal No. 311 of 1998 and 395 of 1998.
3. By the impugned judgment, the High Court dismissed Criminal Appeal No. 311 of 1998 preferred by the appellants, Ramkishan Digambar Jadhav (accused No. 1)2[Hereinafter, referred to as “appellant-Ramkishan”.], Digambar Narba Jadhav (accused No. 2)3[Hereinafter, referred to as “appellant-Digambar”.], and Venkat (accused No. 5)4[Hereinafter, referred to as “appellant-Venkat”.], thereby affirming their conviction and sentence for the offences punishable under Sections 498-A and 304-B read with Section 34 of the Indian Penal Code, 18605[For short, “IPC”.].
4. At the same time, the High Court partly allowed Criminal Appeal No. 395 of 1998 filed by the State of Maharashtra6[Hereinafter, referred to as “respondent-State”.] by setting aside the partial acquittal of the appellant-Ramkishan by the trial Court, and convicted him for the offence punishable under Section 302 of the IPC for the murder of his wife Vimalbai, and sentenced him to imprisonment for life with a fine of Rs.5,000/- with a default stipulation, while maintaining the acquittal of accused Nos. 2 to 6 under Section 302 read with Section 34 of the IPC.
5. Criminal Appeal No. 1849 of 2013 has been preferred by the appellant-Ramkishan, whereas Criminal Appeal No.962 of 2014 has been preferred by co-convicts Digambar and Venkat before this Court. Ramkishan and Venkat are the sons of Digambar.
6. At the outset, it is pertinent to note that the appellant-Digambar in Criminal Appeal No. 962 of 2014 passed away during the pendency of the appeal and hence the appeal qua him stands abated.
BRIEF FACTS
7. Succinctly stated, the facts relevant and essential for disposal of these appeals are noted hereinbelow.
8. The marriage of the appellant-Ramkishan with Smt. Vimalbai7[Hereinafter, also referred to as “deceased-Vimalbai”] was solemnised on 12th May, 1995. The prosecution alleges that, shortly after marriage, Smt. Vimalbai was subjected to continuous harassment, maltreatment, and physical as well as mental torture at the matrimonial home in connection with unlawful demands for dowry, specifically comprising a television set, a tape deck, a plot of land in the MIDC area, and cash amounting to Rs. 50,000/-, so that the husband, i.e. the appellant-Ramkishan could get some employment. However, within barely nine months of the marriage, on 1st February, 1996, Smt. Vimalbai met an unnatural and homicidal death at the matrimonial home.
9. The prosecution also alleges that whenever the deceased-Vimalbai visited her parental home, she used to complain to her brother Narayan, the first informant (PW-2)8[Hereinafter, referred to as “complainant-Narayan”], that the accused persons were coercing her with unlawful demands for cash and other valuables, and that she was being subjected to unrelenting harassment and humiliation on this account.
10. The complainant-Narayan expressed his inability to meet these demands and sent his sister back to the matrimonial home after consoling her. On 12th January, 1996, Smt. Vimalbai had been brought to the parental home on the festival of Sankrant. Even at that time, she complained of maltreatment at the matrimonial home. She also expressed that she was being beaten and was being starved. On one occasion, she was strung with a rope and was hung in the well with a threat that if the demands were not met, she would be killed.
11. In the early hours of 1st February, 1996, at about 01:00 a.m, the appellant-Ramkishan came to the house of the complainant-Narayan and informed him that Smt. Vimalbai was experiencing convulsions and was being taken to Naigaon for medical treatment. On hearing so, the complainant-Narayan, accompanied by his father Ramrao, mother Anjanabai, brother Chandrapra
