Citing Lack of Evidence and Flawed High Court Reasoning, SC Overturns Murder Conviction

This appeal arose agrieved by the High Court of Chhattisgarh's order which reversed the Trial Court's acquittal of the appellant, Jagdish Gond, who was prosecuted under Section 302 of the Indian Penal Code, 1860 (IPC), for allegedly murdering his wife. The Trial Court acquitted the appellant and ruled that the death of the wife, within two years of marriage, was a suicide and no circumstances suggested the guilt of the accused.

The High Court, confirming the acquittal of the in-laws, held the husband guilty on his inability to satisfactorily explain the death of his wife at their common home and disbelief of his alibi of absence due to work. The death had been first entered as one of sudden and unnatural occurrence under Section 174 of Code of Criminal Procedure, 1973 (Cr.PC), on intimation by the husband.

The Supreme Court examined if the High Court was wrong in overturning the acquittal of the Trial Court, particularly in light of the initial information made available by the husband himself, the absence of suspicion raised at the inquest, and the inconclusive medical evidence on the cause of death being homicide. The Apex Court observed that the High Court had set aside the acquittal mainly on the grounds of the failure of the appellant to establish his alibi and the presumption under Section 106 of the Indian Evidence Act, 1872, relating to explanation of facts within special knowledge.

The Supreme Court emphasized the emphasized the legal propostion that an acquittal should not be reversed unless there is manifest illegality or perversity in the Trial Court's conclusions, particularly when two views are possible and the Trial Court's view is plausible. The Apex Court held the High Court's belief solely in the unsubstantiated alibi and lack of explanation inadequate to hold anyone guilty, particularly when the husband had notified the police forthwith and his non-availability from home during the occurrence had been mentioned in the very first intimation.

Supreme Court also made a distinction regarding the application of Section 106 of the Evidence Act to the point that while it may be a strong situation, it is not enough to be the point of conviction on its own, It Further emphasized the absence of conclusive medical opinion linking homicide and a chain of circumstances clearly pointing towards the guilt of the husband.

Finally, the Apex Court did not see strong reasons to reverse the judicious acquittal by the Trial Court, particularly when there was no conclusive evidence to prove homicide or the involvement of the husband in his wife's death. Supreme Court thus permitted the appeal, reversed the High Court judgment, and reinstated the order of acquittal passed by the Trial Court.

CORAM: JUSTICE SUDHANSHU DHULIA & JUSTICE K. VINOD CHANDRAN
BETWEEN: Jagdish Gond VS The State of Chhattisgarh and Ors 2025 INSC 460 (Non Reportable)
DATE OF JUDGMENT: 07-04-2025