Case Note & Summary
The appellant, Satish Hiranna Pujari, was convicted by the Sessions Court for the murder of his wife under Section 302 IPC and sentenced to life imprisonment. The prosecution case was that on the night of the incident, the appellant was seen with his wife at 7 p.m. by PW-2, the landlady. At 10 p.m., PW-2 found the door bolted from outside and discovered the deceased lying motionless. The appellant was arrested soon after. The trial court convicted him based on circumstantial evidence. On appeal, the High Court examined the evidence of nine prosecution witnesses. PW-1, the mother of the deceased, did not witness the incident. PW-2's testimony was found unreliable as she claimed to have seen the appellant at 7 p.m. but also stated she went to sleep at 9 p.m. and later found the door bolted. The court noted that there was no evidence to prove that the appellant was the last person seen with the deceased or that he had any motive. The medical evidence did not establish the time of death conclusively. The High Court held that the chain of circumstances was incomplete and the prosecution failed to prove guilt beyond reasonable doubt. The appeal was allowed, the conviction set aside, and the appellant was acquitted.
Headnote
A) Criminal Law - Murder - Circumstantial Evidence - Section 302 Indian Penal Code, 1860 - The appellant was convicted for murder of his wife based on circumstantial evidence. The High Court held that the prosecution failed to prove the chain of circumstances conclusively pointing to the guilt of the appellant. The evidence of PW-2 and PW-1 was not reliable and there was no direct evidence. The court acquitted the appellant giving him benefit of doubt. (Paras 1-7)
Issue of Consideration
Whether the conviction of the appellant under Section 302 of the Indian Penal Code for the murder of his wife is sustainable based on the evidence on record.
Final Decision
Appeal allowed. Conviction and sentence set aside. Appellant acquitted of offence under Section 302 IPC. Fine, if paid, to be refunded.
Law Points
- Circumstantial evidence must be complete and point only to guilt
- Benefit of doubt in absence of direct evidence
- Conviction cannot be based on suspicion
