In a significant ruling, the Supreme Court has cautioned against applying the traditional burden of proof in criminal cases too rigidly. The court observed that such an inflexible approach could allow perpetrators of serious crimes to evade punishment, ultimately harming society.
A bench comprising Justices Sanjay Kumar and Alok Aradhe made these remarks while reinstating the conviction of an individual from Madhya Pradesh who had been acquitted by the state high court. The accused was convicted of murdering his daughter-in-law 27 years prior. The Supreme Court reiterated that while prosecutors generally must prove guilt beyond a reasonable doubt, Section 106 of the Evidence Act mandates that an accused must offer explanations for facts that are within their specific knowledge. A failure to do so can significantly bolster the prosecution’s case.
“The traditional rule relating to burden of proof of the prosecution cannot be allowed to be wrapped in a pedantic coverage; the offenders in serious offences would be the major beneficiaries and the society would be the casualty,” the bench stated. They further noted that the false explanation provided by the accused served as an additional piece of evidence connecting him to the crime.
The case involved an appeal by the state against a 2010 Madhya Pradesh High Court judgment that had overturned the convictions of Janved Singh and his son, Mahesh Singh, for the dowry death of Janved’s daughter-in-law, Pushpa. Previously, a sessions court had sentenced Janved to life imprisonment for murder, dowry harassment, and destruction of evidence.
Pushpa was discovered dead in her home in December 1997, shortly after her marriage to Mahesh. Her father-in-law, Janved, initially informed the police that she had died from electrocution while ironing. However, the post-mortem examination revealed ligature marks indicative of strangulation, and the burn injuries were found to be post-mortem. The trial court dismissed the electrocution theory as fabricated, deeming the death to be a homicide.
The high court, however, had overturned the conviction, citing doubts about the prosecution’s evidence and a lack of proof that the death occurred within seven years of marriage, a requirement for dowry death charges under Section 304B of the Indian Penal Code. The high court also critiqued the delay in recording statements from Pushpa’s parents and the late seizure of the wedding invitation card.
In its decision, the Supreme Court reversed the high court’s ruling, finding that it had overlooked crucial evidence and failed to consider the trial court’s reasoning. The bench emphasized that when a death occurs within a home, and the accused provides a fabricated explanation, this falsehood itself becomes a significant factor in establishing guilt.
“The accused lodged a false report of electrocution and attempted to mislead the investigation. The explanation that he returned from the field to find the deceased dead is not supported by any witness. Once the prosecution proved that the death occurred in his house, the burden was on him to explain the circumstances, which he failed to do,” the Court noted.
The evidence, including the doctor’s testimony confirming strangulation, the false electrocution report, indications of marital discord, and persistent dowry demands, collectively formed an unbroken chain pointing solely to the accused’s guilt, the bench concluded.
Consequently, the Supreme Court set aside the high court’s acquittal and ordered Janved Singh’s immediate arrest to serve the remainder of his life sentence.
The court poignantly remarked, “The law often steps into homes not to witness celebration, but to lift the veil from grief.” This statement underscored the judicial responsibility to ensure that justice prevails and that individuals do not escape culpability due to procedural technicalities when the evidence clearly indicates guilt.