Supreme Court acquits accused in alleged strangulation case: State of Karnataka vs. Srinivasa (2018)

Date of the Judgment: 14th August, 2018
Citation: (2018) INSC 723
Judges: R. Banumathi, J., Vineet Saran, J.

Can a conviction for murder be overturned if medical evidence suggests the possibility of suicide? The Supreme Court of India recently addressed this question in a case where the accused was initially convicted of strangulating his wife, but later acquitted by the High Court. This case highlights the critical role of medical evidence in criminal trials, especially when determining the cause of death. The Supreme Court upheld the High Court’s decision, acquitting the accused, emphasizing the importance of a plausible view based on the evidence presented. The judgment was delivered by a bench comprising of Justice R. Banumathi and Justice Vineet Saran.

Case Background

The case revolves around the death of Rajashree, who was found dead in her home on January 5, 2001. Her husband, Srinivasa (A-1), was accused of strangling her to death due to his alleged illicit relationship with Padmavathi (A-2), who was employed in his power loom business. The prosecution argued that the illicit relationship led to frequent quarrels between Srinivasa and Rajashree. On the day of the incident, Rajashree was found hanging with a telephone cable wire. Initially, the trial court convicted Srinivasa under Section 302 of the Indian Penal Code, 1860 (IPC) for murder and sentenced him to life imprisonment. Padmavathi was convicted under Section 201 of the IPC for causing disappearance of evidence and was sentenced to three years of imprisonment. However, Padmavathi’s appeal was abated due to her death during the pendency of the appeal.

Timeline:

Course of Proceedings

The Trial Court, relying on the medical evidence and the testimony of the deceased’s father (PW-8), convicted Srinivasa under Section 302 of the Indian Penal Code, 1860 (IPC) for murder and also sentenced him to undergo life imprisonment. The Trial Court also convicted Padmavathi under Section 201 of IPC and sentenced her to undergo three years imprisonment. The High Court, however, overturned the conviction. The High Court based its decision on the post-mortem report and the testimony of the doctor (PW-7), who stated that the ligature mark was not consistent with strangulation and that suicide could not be ruled out. The High Court concluded that the medical evidence did not conclusively establish a homicidal death, and thus, the accused was entitled to the benefit of the doubt. The State of Karnataka then appealed to the Supreme Court against this acquittal.

Legal Framework

The primary legal provision in this case is Section 302 of the Indian Penal Code, 1860 (IPC), which defines the punishment for murder. Section 302 of the IPC states: “Punishment for murder.—Whoever commits murder shall be punished with death, or imprisonment for life, and shall also be liable to fine.” Additionally, Section 201 of the IPC deals with causing disappearance of evidence of offence, or giving false information to screen offender. Section 201 of the IPC states: “Causing disappearance of evidence of offence, or giving false information to screen offender.—Whoever, knowing or having reason to believe that an offence has been committed, causes any evidence of the commission of that offence to disappear, with the intention of screening the offender from legal punishment, or with that intention gives any information respecting the offence which he knows or believes to be false, shall be punished with imprisonment of either description for a term which may extend to seven years, and shall also be liable to fine; and if the offence which he knows or believes to have been committed is punishable with death, shall be punished with imprisonment of either description for a term which may extend to ten years, and shall also be liable to fine.”

Arguments

Arguments by the State of Karnataka:

• The State argued that the trial court had correctly convicted the accused based on the evidence of the deceased’s parents (PW-8 and PW-9), who testified about the illicit relationship between the accused and Padmavathi, and the frequent quarrels between the accused and the deceased.
• The State also contended that the medical evidence should not be the sole basis for overturning the conviction, and that the other evidence should also be considered.

Arguments by the Respondent (Srinivasa):

• The respondent relied on the High Court’s findings that the medical evidence did not conclusively establish a homicidal death.
• The respondent argued that the doctor’s (PW-7) testimony, stating that suicide could not be ruled out, was crucial in determining the cause of death.
• The respondent argued that the High Court’s view was a plausible view based on the evidence.

Issues Framed by the Supreme Court

• Whether the High Court was justified in acquitting the accused based on the medical evidence, when the trial court had convicted him based on other evidence?

Treatment of the Issue by the Court:

Authorities

The Supreme Court did not cite any specific legal precedents in this judgment. The primary focus was on the interpretation of the medical evidence and the plausibility of the High Court’s view.

Judgment

How each authority was viewed by the Court?

• Evidence of PW-7 (Doctor): The court relied heavily on the doctor’s testimony that suicide could not be ruled out, which formed the basis of the High Court’s decision to acquit the accused.

What weighed in the mind of the Court?

The Supreme Court’s decision was primarily influenced by the medical evidence presented by PW-7, the doctor who conducted the post-mortem. The doctor’s testimony that suicide could not be ruled out was crucial. The court also emphasized that when the High Court has taken a plausible view based on the evidence, there is no compelling reason for the Supreme Court to interfere with the order of acquittal. The court’s decision reflects a preference for upholding the High Court’s judgment when it is based on a reasonable interpretation of the evidence, particularly in cases where the medical evidence is not conclusive.

Logical Reasoning:

The court considered the possibility of alternative interpretations of the evidence but ultimately rejected them. The court agreed with the High Court’s assessment that the medical evidence did not conclusively prove a homicidal death, and the possibility of suicide could not be ruled out. The court noted that when the High Court has taken a plausible view based on evidence, there is no compelling reason to interfere with the order of acquittal. The court’s decision was based on the principle that in criminal cases, the burden of proof lies with the prosecution, and if there is reasonable doubt, the benefit of the doubt should go to the accused.

The Supreme Court stated, “When the doctor has given opinion that the suicide cannot be ruled out and the death of the deceased could have been due to suicide which was accepted by the High Court; when the High Court has a view which is a plausible view, we find no good ground to take a different view.” The Court also stated, “After appreciating the oral evidence and medical evidence, the High Court acquitted the accused.” The Court further stated, “In view of above, we do not find any compelling reason or substantial ground to interfere with the order of acquittal.”

There were no dissenting opinions in this case. The decision was unanimous, with both judges agreeing that the High Court’s acquittal should be upheld.

The Supreme Court’s decision highlights the importance of medical evidence in criminal trials, especially in cases involving the cause of death. It also underscores the principle that when a High Court’s decision is based on a plausible interpretation of the evidence, the Supreme Court should be hesitant to interfere with that decision. The case reinforces the principle of “benefit of doubt” in criminal law.

Key Takeaways

• Medical evidence plays a crucial role in determining the cause of death in criminal cases.
• If medical evidence is inconclusive or suggests the possibility of suicide, the accused may be given the benefit of the doubt.
• The Supreme Court is generally hesitant to interfere with a High Court’s decision when it is based on a plausible view of the evidence.
• The burden of proof lies with the prosecution, and any reasonable doubt should benefit the accused.

Directions

No specific directions were given by the Supreme Court in this judgment.

Development of Law

The ratio decidendi of this case is that when the medical evidence does not conclusively establish a homicidal death and the possibility of suicide cannot be ruled out, the accused is entitled to the benefit of the doubt. This case reinforces the importance of medical evidence in criminal trials and the principle that the benefit of doubt should go to the accused. There is no change in the previous position of law.

Conclusion

In the case of State of Karnataka vs. Srinivasa, the Supreme Court dismissed the appeal by the State of Karnataka and upheld the High Court’s decision to acquit the accused, Srinivasa. The court emphasized that the medical evidence did not conclusively establish a homicidal death and that the possibility of suicide could not be ruled out. The court also noted that the High Court had taken a plausible view based on the evidence and that there was no reason to interfere with the order of acquittal. This case underscores the importance of medical evidence in criminal cases and the principle that the benefit of doubt should be given to the accused when the evidence is not conclusive.