The Supreme Court of India has acquitted a man convicted of murdering his wife, stating that “mere suspicion cannot lead to a finding of guilt”, especially in the absence of a complete chain of evidence. The verdict was delivered by a two-judge Bench comprising Justice Sudhanshu Dhulia and Justice K. Vinod Chandran, which allowed the criminal appeal filed by the husband against the Chhattisgarh High Court’s conviction under Section 302 of the IPC.
“SUSPICION CAN NOT TAKE THE PLACE OF PROOF”, RULES SUPREME COURT
“A mere suspicion cannot lead to a finding of guilt, especially when there is no available chain of circumstances, unequivocally pointing to the guilt of the accused in the alleged crime, as has been held in Sharad Birdhichand Sarda v. State of Maharashtra,” the Court observed.
BACKGROUND OF THE CASE
The appellant-husband found his wife lying unresponsive on a cot at their residence after returning home from work. He immediately informed his nearby parents and alerted the police, leading to a case being registered under Section 174 CrPC (sudden and unnatural death). At that stage, no suspicion was raised.
Subsequently, a complaint by the deceased’s father led to an FIR, and charges under Sections 498A, 306 r/w Section 34 IPC were framed. The Trial Court acquitted all accused, concluding the wife had committed suicide and there was no direct or circumstantial evidence of homicide.
However, the High Court reversed the husband’s acquittal, convicting him under Section 302 IPC solely based on a discredited alibi and the fact that the couple lived together.
SUPREME COURT RESTORES ACQUITTAL
The Apex Court set aside the High Court’s conviction, reaffirming that the burden of proof rests on the prosecution and cannot be replaced by presumptions or incomplete circumstantial evidence.
“The death; not unequivocally proved to be a murder, of a young woman, married for two years, led to the prosecution of her husband and in-laws,” the Court noted.
The Bench held that the alibi provided by the accused—that he was on duty when the incident occurred—was plausible and unrefuted, and thus not enough to trigger Section 106 of the Indian Evidence Act.
“We find that there was not enough material to upset the order of acquittal of the Trial Court, especially when there was also no evidence led regarding the death being a result of homicide.”
NO CIRCUMSTANTIAL CHAIN PROVING GUILT
The Court emphasized that there was no complete chain of circumstances establishing the guilt of the accused:
“There is not a single circumstance pointing to the guilt of the accused, leave alone, a chain of circumstances fully establishing the guilt of the accused and excluding every possible hypothesis, except that of guilt.”
Further, the Bench noted:
“True, the young woman, who was married just two years back died, tragically, at the house of the husband. There is no evidence to show that the husband was available on the ill-fated night when the death occurred. The husband–accused had a plausible explanation that he was on duty when the death of his wife occurred. It was the husband who first intimated the police about the sudden and unnatural death of his wife.”
Relatives of the deceased, who had arrived at the house on the same day, did not raise suspicion regarding the nature of the death.
FINAL VERDICT
In conclusion, the Supreme Court held:
“Having found no circumstance leading to the guilt of the accused, we are unable to sustain the order of the High Court, which we set aside and restore the order of acquittal of the Trial Court.”
OUTCOME
- Appeal allowed
- High Court’s conviction set aside
- Trial Court’s acquittal restored
- Accused husband acquitted
Case Title: Jagdish Gond v. The State of Chhattisgarh and Ors.
Neutral Citation: 2025 INSC 460
