Supreme Court restores conviction of father-in-law for daughter-in-law’s 1997 murder, overturning Madhya Pradesh High Court’s acquittal based on complete circumstantial evidence and Section 106 burden.

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Case Overview

Case Name: State Of Madhya Pradesh vs. Janved Singh

A Bench of the Supreme Court of India comprising Justice Sanjay Kumar and Justice Alok Aradhe set aside the Madhya Pradesh High Court’s Gwalior Bench judgment acquitting a father-in-law accused in the 1997 murder of his daughter-in-law . The deceased was found dead under suspicious circumstances inside her matrimonial home . While the accused claimed accidental electrocution, medical evidence confirmed death by strangulation . The Sessions Court had earlier convicted him for murder, cruelty, and destruction of evidence, but the High Court had acquitted him in 2010 .

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Key Aspects

Before the Supreme Court, the State argued that the acquittal was based on misappreciation of evidence . The Court meticulously analyzed the chain of circumstances to establish guilt .

• The deceased died inside the house controlled by the accused .
• Medical reports confirmed strangulation and post-mortem burn marks .
• The accused filed a false FIR of electrocution to mislead investigators .
• Evidence of dowry demands and strained relations strengthened the prosecution’s case .

Legal Insights

The Court examined statutory provisions relevant to circumstantial and burden-of-proof cases .

• Section 106 of the Indian Evidence Act, 1872 – places the burden on the accused to explain facts “especially within his knowledge,” such as incidents inside his own home .
• Section 302 of the Indian Penal Code, 1860 – defines the punishment for murder .
• The Court reaffirmed that misappreciation of evidence can justify reversing an acquittal under appellate powers .
• It emphasized that false explanations and deliberate misleading acts form key links in circumstantial evidence cases .

Court’s Verdict

The Supreme Court of India restored the trial court’s conviction, holding that the prosecution proved guilt beyond reasonable doubt . The appeal filed by the State of Madhya Pradesh was allowed and the murder acquittal overturned .

Source – Supreme Court of India 

Read also – Indian Penal Code, 1860 

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