The court reaffirmed that, in criminal cases, the prosecution must establish guilt beyond reasonable doubt, particularly in circumstantial evidence cases. Failure to meet this standard leads to acquittal.

Headnote:(A) Indian Penal Code, 1860 - Sections 302 and 201 - Conviction and sentence - The accused was convicted for murder and destruction of evidence. Evidence suggests the accused and deceased had a strained relationship marked by quarrels due to suspicions of infidelity. However, causation of death and presence of the accused at the time of the incident were not proven beyond reasonable doubt. (Paras 18, 26, 34)

(B) Evidence - Burden of proof - The prosecution failed to establish the presence of the accused in the house at the time of death, nor could they conclusively prove the cause of death. The absence of medical testimony to clarify the autopsy findings raised fatal weaknesses in the prosecution's case. (Paras 27, 37)

(C) Circumstantial evidence - Standard of proof - In a circumstantial case, the chain of evidence must lead only to the guilt of the accused without leaving any reasonable doubt. Here, the court found the prosecution evidence insufficient for conviction. (Paras 32, 38)

Facts of the case:
The accused and the deceased, after living together, had a quarrelsome relationship exacerbated by alcohol consumption. The deceased was found dead under suspicious circumstances with burn injuries and suspected strangulation. Key witnesses turned hostile affecting the prosecution case (Paras 3, 7, 8).

Findings of Court:
The court ruled that the prosecution could not prove that the deceased was murdered or that the accused was present during her death, necessitating the acquittal of charges. (Paras 31, 36).

Issues: The primary issues included the proof of presence of the accused during the time of death and the establishment of a clear cause of death (Paras 26, 27).

Ratio Decidendi: The court concluded that the failure to definitively prove the cause of death and the presence of the accused at the time raised reasonable doubt, leading to the acquittal of the accused based on the principle of benefit of doubt (Paras 25, 38).

Result: Appeal is allowed. The conviction and sentence are set aside; the accused is acquitted.

Table of Content
1. incident details leading to death. (Para 3 , 4 , 5)
2. witness testimonies and their reliability. (Para 8 , 10 , 12)
3. causation of death and evidence evaluation. (Para 18 , 26)
4. circumstantial evidence requirements. (Para 31 , 32)

(PER: HON'BLE MR. JUSTICE MOHAMMAD NAWAZ)

This appeal is preferred by the accused against the Judgment and order of conviction and sentence passed against him by the Court of Principal Sessions Judge, Kolar dated 30.11.2017 and 05.12.2017, whereby the learned Sessions Judge has convicted him for the offence punishable under Section 302 and 201 of IPC . He was sentenced to undergo rigorous imprisonment for life and to pay a fine of Rs.10,000/- for the offence punishable under and in default to pay the fine amount, to further undergo SI for a period of 6 months. He was sentenced to undergo RI for a period of 2 years and to pay a fine of Rs.1,000/-, in default to pay the fine amount, to further undergo SI for a period of 3 months.

2. Heard the learned counsel for appellant, learned Additional SPP for the State and perused the evidence and material on record.

3. The case of prosecution is that deceased Babamma after deserting her husband and children, developed illicit relationship with the accused, a resident of Puttenahalli Village and thereafter started residing with him. Both of them used to go to Bengaluru for coolie work from Puttenahalli and whenever they visited their village they used to pick up quarrel and they were also addicted to alcohol. On 28.06.2015, at about 03.30 p.m., accused quarrelled and assaulted the deceased suspecting her fidelity and in the night at about 09.00 p.m., he made the deceased to drink alcohol and caused burn injuries on her forehead, chin, below the neck, on the chest, on the left and right shoulders and other parts of the body and near the private part, with a burning firewood and shoved the hittu kolu (used for preparing ragi ball) into her private part and strangulated her to death. Further, after committing the murder, with an intention of screening himself from legal punishment, he burnt the clothes of the deceased near his house and thereby, committed the charged offences punishable under Section 302 and 201 of IPC .

4. According to prosecution, the incident took place on 28.06.2015 at about 09.00 p.m. Brother of the deceased by name Somappa(PW1) lodged a complaint on 30.06.2015, marked as ExP1. Based on the said complaint, PW14-PSI, Nangali Police Station registered a case in Crime No.81/2015 and transmitted the FIR-ExP14 to the jurisdictional Court.

5. In Ex.P1, it is stated that after the deceased had deserted her husband and children, she had developed intimacy with the accused and she was living along with him for the last 6 to 7 years in the house of one Venkatarama. Both of them were visiting Bengaluru for coolie work and whenever they returned to the village, they used to quarrel among themselves and they were also consuming alcohol. On 28.06.2015 at about 03.30 p.m. after returning from Bengaluru, deceased and accused stayed in their house and at about 09.00 p.m., they quarrelled with each other and accused assaulted the deceased, brought her clothes outside the house and burnt it and committed her murder, closed the door and went away.

6. As per ExP1, on 29.06.2015 at about 05.30 p.m., a neighbour by name Reddamma (PW2) raising suspicion, as there were dogs near the house, went and peeped through the door and noticed the dead body of Babamma lying inside the house with bleeding injuries. She informed the matter to the villagers and one Narayanappa bin Thippanna informed the same to the complainant.

7. It is the specific case of the prosecution that the deceased and the accused were living together in Puttenahalli village, in the house of one Venkatarama and they used to go to Bengaluru for coolie work and return to the village. They were addicted to alcohol and both of them were quarreling with each other. The accused was suspecting the fi

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2026 Supreme(Online)(Kar) 8903

THE HIGH COURT OF KARNATAKAMohammad Nawaz, JSRI VENKATARAVANA @ VENKTARAMA – AppellantVersusSTATE OF KARNATAKA – RespondentSessions Case No.201/2015

The court reaffirmed that, in criminal cases, the prosecution must establish guilt beyond reasonable doubt, particularly in circumstantial evidence cases. Failure to meet this standard leads to acquittal.

Cases Referred (2)

THE HIGH COURT OF KARNATAKA
Mohammad Nawaz, J
SRI VENKATARAVANA @ VENKTARAMA – Appellant
Versus
STATE OF KARNATAKA – Respondent
Sessions Case No.201/2015