Deceased Wife Had Become Stumbling Block In Their Incestous Relationship: SC Upholds Murder Conviction Of Husband, His Aunt & Uncle
The Supreme Court upheld the conviction of a man, along with his aunt and uncle, for the murder of his wife, who had become a "stumbling block" in the man's alleged incestuous relationship with his aunt.
The Court upheld the reversal of acquittal by the Madras High Court. The prosecution’s case detailed an illicit relationship between the accused that led to the murder of his wife. The prosecution’s case was that the complaint revealed glaring details of the disturbing circumstances and troubles that the deceased was being subjected to by the Appellants at the time of her marriage and the said details were substantiated and corroborated by witnesses.
A Bench of Justice Bela M. Trivedi and Justice Satish Chandra Sharma held, “There is also enough evidence adduced by the Prosecution to hold that the Appellants had the clear motive to eliminate the Deceased. An illicit/incestuous relationship between Ms. Uma and Mr. Ravi had become known to the Deceased Rajalakshmi & her family, and she had become a stumbling block in the relationship, which swelled the common intention of the Appellants to murder her. The factum that the Deceased has passed away within six months of her marriage also becomes a relevant consideration to attribute culpable intent of the Appellants. Although, the motive of Mr. Balasubramanian remains unclear, his aid & assistance in the commission of the crime cannot be ruled out.”
Senior Advocate Kathirvelu represented the appellants, while Senior Advocate N.R. Elango appeared for the respondent.
The Trial Court concluded that the prosecution's case was not proved beyond reasonable doubt, and hence, the Appellants were entitled to an acquittal. It was observed that despite the medical evidence on record, Courts can prefer to accept eyewitness testimony(ies) in preference to the opinion of a medical expert. In the absence of any direct ocular evidence, the Trial Court did not consider it appropriate to award due to the medical evidence.
However, the High Court reversed the findings of the Trial Court and convicted the Appellants for inter alia the murder of the deceased under Section 302 of the IPC.
The Supreme Court noted that the prosecution’s case rested on circumstantial evidence, testimonies of witnesses read with the reports of medical examination, however, there were no direct eyewitnesses to the incident.
The Court referred to its decision in Sharad Birdhichand Sarda v. State of Maharashtra (1984) which outlined the five golden principles constituting the ‘panchsheel of proof’ for a case based on circumstantial evidence. It was held that “insofar as the facts so established should be consistent only with the hypothesis of the guilt of the accused, and the circumstances should be of a conclusive nature and tendency; they should exclude every possible hypothesis except the one to be proved; there must be a chain of evidence so complete as not to leave any reasonable ground for the conclusion consistent with the innocence of the accused and must show that in all human probability the act must have been done by the accused.”
“The prosecution has proved its case beyond reasonable doubt, established the complete chain of circumstances including the; (i) motive (ii) presence of the Appellants at the time of incident (iii) false explanation in the statement under Section 313 of the CrPC (iv) the conduct of the Appellants before and after the incident & most pertinently (v) the medical evidence; which in all human probability only correspond to the guilt of the Appellants,” the Court in the present case stated.
Consequently, the Court held that there was enough evidence adduced by the Prosecution to hold that the Appellants had a clear motive to eliminate the Deceased. “We are hence of the opinion that the Prosecution has been able to prove its case beyond reasonable doubt that the Accused Nos. 1 and 2, with the aid & support of the Accused No.3 have murdered the deceased Rajalakshmi and strangulated her to death,” it held.
Accordingly, the Supreme Court dismissed the appeal.
Cause Title: Uma & Anr. v. The State Rep. By The Deputy Superintendent Of Police (Neutral Citation: 2024 INSC 809)
Appearance:
Appellants: Senior Advocate Kathirvelu; AOR T.R.B. Sivakumar, Vairawan A.S, and P. Soma Sundaram; Advocates Beno Bencigar, Jeyamohan, Sudhakaran, Alagiri Karunanidhi and Rohan Singh
Respondent: Senior Advocate N.R. Elango; AOR Sabarish Subramanian and P.V. Yogeswaran; Advocates C. Kranthi Kumar, Vishnu Unnikrishnan, Naman Dwivedi, Sarathraj B and Danish Saifi