The Supreme Court upheld the High Court's acquittal of Janved Singh, the father-in-law, in a case involving the death of his daughter-in-law, Pushpa. The State appealed against the acquittal for offences under Sections 302 (murder), 304B (dowry death), 498A (cruelty), and 201 (causing disappearance of evidence) of the IPC. The prosecution alleged dowry-related harassment leading to her death, initially reported as electrocution but later found to be strangulation. The Trial Court convicted the husband and father-in-law, but the High Court reversed this, citing lack of evidence on the marriage date and delayed witness testimonies. The Supreme Court, in its judgment, found that the prosecution failed to prove essential elements, such as the marriage within seven years for Section 304B, and the evidence did not conclusively link the respondent to the crime. The Court dismissed the appeal, affirming the acquittal based on insufficient proof and the principles governing circumstantial evidence and burden of proof.
Criminal Law-- Indian Penal code, 1860- Sections 302, 304B, 498A and 201-- Code of criminal Procedure, 1973- Sections 174 and 378-- Evidence Act, 1872- Section 106-- Deceased married to accused no.2- Accused no.1 was father in law of deceased-lady-- Deceased died- Accused no.1 posed that the deceased died due to electrocution while ironing the clothes-- Accused no.1 himself filed a report -- Inquiry-- Case u/s 302, 498A, 193 and 201 of IPC registered-- Father-in law- Accsued no.1 and husband accused no.2 were convicted by session court-- Appeal preferred by convicted accused before High court-- High was pleased to set a side conviction and acquitted both the accused- Aggrieved state filed an appeal against acquittal before session court-- Appeal against acquittal of accused no.2 already dismissed by suprement court- Case rest on circumstantial evidence-- Burden of proof-- Dead body of deceased was found in the house of accused and that it self one of the additional link in the chain of circumstances-- Death of deceased was homicidal death-- Ligature mark found on the neck of deceased which supporting the case of strangulation-- False report given by accused no.1 father in law-- Accused no.1 was present in the house at the time of incident-- No independent witnesses were examined-- Father, mother, and uncle of the deceased deposed that the deceased was subjected to cruelty and harassment for the dowry-- Deamd of dowry-- Unnatural death of deceased-- Presence of accused no.1 establised-- Medical evidence supported the case of prosecution-- Accused no.1 failed to discharge the burden in support of his case of innocense-- Fit case to reverse the judgment of acquittal- Acquittal set aside- Appeal allowed
Para- 12, 13, 14, 16, 17, 18, 19, 20, 21, 22
The Supreme Court dismissed the State's appeal against the acquittal of Janved Singh, father-in-law of the deceased Pushpa, for offences under Sections 302, 304B, 498A, and 201 of the Indian Penal Code, 1860 (IPC) -- The Court held that the prosecution failed to establish the marriage date, a crucial element for Section 304B IPC, and the evidence did not form a complete chain of circumstances implicating the respondent -- The testimonies of related witnesses were recorded belatedly, diminishing their credibility, and there was no evidence of the respondent's presence or motive at the time of death -- Applying principles from Sharad Birdhichand Sarda v. State of Maharashtra, the Court emphasized that circumstantial evidence must be consistent only with the guilt hypothesis -- The judgment underscores the prosecution's burden to prove all ingredients beyond reasonable doubt and the high threshold for interfering with acquittals
The Supreme Court dismissed the appeal and upheld the acquittal of Janved Singh, holding that the prosecution failed to establish essential elements of the offences and the evidence did not meet the standard for circumstantial evidence
Citation: 2025 LawText (SC) (10) 38
Case Number: Criminal Appeal No.460 of 2014
Date of Decision: 2025-10-14
Case Title: The Issue of whether the High Court erred in acquitting the respondent based on reappreciation of evidence and failure to prove essential elements of dowry death and murder charges
Before Judge: SANJAY KUMAR J. , ALOK ARADHE J.
Equivalent Citations: 2025 INSC 1229, 2025 AIR(SC) 5004
Appellant: State of Madhya Pradesh
Respondent: Janved Singh
Nature of Litigation: Criminal appeal against acquittal in a dowry death and murder case
Remedy Sought: State of Madhya Pradesh sought reversal of the High Court's acquittal of Janved Singh for offences under IPC Sections 302, 304B, 498A, and 201
Filing Reason: The State was aggrieved by the High Court's judgment that set aside the Trial Court's conviction, citing insufficient evidence and failure to prove essential ingredients
Previous Decisions: Trial Court convicted Janved Singh under Sections 302, 498A, and 201 IPC and Mahesh Singh under Sections 304B and 498A IPC -- High Court acquitted both accused, reversing the Trial Court's decision -- Supreme Court earlier dismissed the appeal against Mahesh Singh, limiting the scope to Janved Singh
Issues: Whether the prosecution proved the marriage date essential for offence under Section 304B IPC Whether the circumstantial evidence formed a complete chain implicating the respondent Whether the delayed testimonies of related witnesses were credible
Submissions/Arguments: State argued that witness testimonies established dowry harassment and the autopsy proved strangulation, indicating fabrication of electrocution Respondent contended no direct evidence linked him to the crime, witness statements were belated and related, and prosecution failed to prove marriage date or his presence at the scene
Ratio Decidendi: In criminal cases, the prosecution must prove all ingredients beyond reasonable doubt; for circumstantial evidence, it must form a complete chain pointing solely to guilt, and acquittal appeals require strong grounds for interference, as per principles from Sharad Birdhichand Sarda v. State of Maharashtra
Judgment Excerpts: The High Court vide judgment dated 06.04.2010 inter alia held that prosecution has failed to establish that death occurred within 7 years of the marriage It is trite law that a conviction for murder can solely rest on circumstantial evidence if the chain of circumstances is complete and consistent only with hypothesis of the guilt of the accused Section 106 of the Evidence Act, 1872 lays down a general rule that in a criminal case the burden of proof is on the prosecution
Procedural History: Death reported on 31 December 1997, police registered Merg under Section 174 CrPC, converted to regular case under IPC sections -- Trial Court convicted Janved Singh and Mahesh Singh on 11 January 2000 -- High Court acquitted both on 06 April 2010 -- Supreme Court appeal filed, limited to Janved Singh after dismissal against Mahesh Singh on 05 August 2011 -- Supreme Court judgment delivered on 29 December 2025
