This is a Supreme Court judgment in Uma & Anr. vs. State (Crl. A. No. 757 of 2015), where the appellants challenged the reversal of their acquittal by the High Court. They were convicted for the murder of Rajalakshmi, primarily under Sections 120B (criminal conspiracy) and 302 (murder) of the IPC. The High Court had overturned the trial court's acquittal and sentenced them to life imprisonment, citing clear evidence of a motive, presence, and medical findings.

1. Introduction & Background (Paras 1-2)
   The appellants, Uma, her husband Ravi, and Balasubramanian, were accused of murdering Rajalakshmi, Ravi’s wife, within six months of marriage. The High Court reversed the trial court's acquittal and convicted them under Sections 120B and 302 IPC, imposing life sentences.

2. Prosecution's Case (Paras 2-7)
   Rajalakshmi was harassed by Ravi, her husband, and Uma, her aunt-in-law, after marriage due to their alleged illicit relationship. On August 23, 2008, she was found dead, and the postmortem revealed that she was strangulated to death.

3. Medical Evidence (Para 8-9)
   Postmortem reports indicated ante-mortem injuries, including a broken hyoid bone, which ruled out suicide by consuming poison or paint, as alleged by the accused. The medical findings pointed to suffocation as the cause of death.

4. Chain of Circumstances (Paras 10-11)
   A sequence of events, supported by witness testimonies (P.W.-1 to P.W.-4), established a clear chain of circumstantial evidence proving that the death was homicidal. The accused were held responsible for the murder.

5. Trial Court’s Acquittal (Paras 12-13)
   The trial court acquitted the accused, citing a lack of direct evidence, and disregarded the circumstantial evidence and motive. It found the motive (illicit relationship) to be artificial and unsupported.

6. High Court’s Reversal (Paras 13-18)
   The High Court disagreed with the trial court, stating that the circumstantial evidence, medical reports, and witness testimonies corroborated the prosecution’s case. The appellants were convicted, as they failed to explain the cause of death under Section 106 of the Indian Evidence Act.

7. Supreme Court’s Analysis & Conclusion (Paras 19-29)
   The Supreme Court upheld the High Court’s findings, emphasizing that the case, though circumstantial, was proven beyond a reasonable doubt. The evidence, including motive, medical reports, and the behavior of the accused, pointed to their guilt.

Acts & Sections Discussed:

• Indian Penal Code, 1860 (IPC):

  • Section 120B: Criminal conspiracy
  • Section 302: Murder
  • Section 201: Causing disappearance of evidence (referenced but not applied)

• Indian Evidence Act, 1872:

  • Section 106: Burden of proving facts within special knowledge of the accused.

• Criminal Procedure Code (CrPC), 1973:

  • Section 313: Examination of accused.

Ratio Decidendi:

The Supreme Court upheld the conviction based on the principle that in cases of circumstantial evidence, a chain of facts must lead only to the guilt of the accused, excluding any possibility of innocence. The appellants' inability to provide an alternative explanation, combined with the clear motive (illicit relationship) and medical findings, led to their conviction.

Subjects:

• Criminal Law
• Murder
• Circumstantial Evidence
• Illicit Relationship
• Family Disputes
• Burden of Proof