Supreme Court Acquits Mother in Newborn Death Case: Manju vs. State of Delhi (2019)

Date of the Judgment: 17 December 2019

Citation: 2019 INSC 1234 (where available)

Judges: Mohan M. Shantanagoudar, J., R. Subhash Reddy, J.

Can a mother be convicted for the murder of her newborn child based solely on circumstantial evidence? The Supreme Court of India recently addressed this critical question in the case of Manju vs. State of Delhi. This case examines the limits of circumstantial evidence in criminal convictions, particularly in emotionally charged cases. The Supreme Court, in this judgment, overturned the conviction of a mother who was accused of killing her newborn baby girl, emphasizing the need for a complete chain of circumstances to prove guilt beyond a reasonable doubt. The judgment was authored by Justice R. Subhash Reddy, with Justice Mohan M. Shantanagoudar concurring.

Case Background

On 24th August 2007, Manju, the appellant, delivered a baby girl at Lady Hardinge Medical College Hospital in Delhi around 12:30 PM. The prosecution alleged that after the baby was handed to Manju at 4:30 PM, she strangled the infant to death because it was a girl. A post-mortem conducted on 26th August 2007 indicated that the cause of death was asphyxia due to ante-mortem strangulation. On 31st August 2007, a case was registered against Manju under Section 302 of the Indian Penal Code (IPC) for causing the death of her newborn.

Timeline

Course of Proceedings

The Additional Sessions Judge, Fast Track Court, New Delhi, tried Manju for the offense under Section 302 of the Indian Penal Code. The trial court found her guilty, stating that the prosecution had established a complete chain of circumstances proving her guilt beyond a reasonable doubt. Manju was sentenced to life imprisonment and fined Rs. 2000. The High Court of Delhi upheld the trial court’s decision, confirming her conviction and sentence. Manju then appealed to the Supreme Court.

Legal Framework

The primary legal provision in this case is Section 302 of the Indian Penal Code (IPC), which deals with the punishment for murder. Section 302 of the Indian Penal Code states, “Whoever commits murder shall be punished with death, or 1[imprisonment for life], and shall also be liable to fine.” The case revolves around whether the prosecution could prove beyond a reasonable doubt that Manju committed murder, primarily through circumstantial evidence.

Arguments

Appellant’s Arguments:

• The appellant argued that there were no eyewitnesses to the incident, and the conviction was based solely on circumstantial evidence. The chain of circumstances was not complete.
• It was contended that the appellant had no motive to kill her newborn baby girl, as she already had a male child and her family was not averse to having a female child.
• The appellant pointed out that the newborn was kept in an incubator with an oxygen mask, and the appellant was sleepy due to the administered drugs. By the time she saw the child, it was already dead.
• The appellant highlighted the delay in conducting the post-mortem (two days after the incident) and registering the crime (seven days after the incident).

State’s Arguments:

• The State argued that the newborn was healthy until handed over to the appellant at 4:30 PM and was found dead shortly after.
• The prosecution contended that although the conviction rested on circumstantial evidence, the chain of circumstances was sufficient to prove the appellant’s guilt.

Issues Framed by the Supreme Court

The primary issue before the Supreme Court was:

1. Whether the circumstantial evidence presented by the prosecution was sufficient to prove the guilt of the appellant beyond a reasonable doubt for the offense under Section 302 of the Indian Penal Code.

Treatment of the Issue by the Court

The following table demonstrates as to how the Court decided the issues:

Authorities

The court considered the following:

• Section 302 of the Indian Penal Code (IPC): This section defines the punishment for murder.

Judgment

How each submission made by the Parties was treated by the Court?

How each authority was viewed by the Court?

• Section 302 of the Indian Penal Code (IPC): The court used this provision to assess whether the prosecution had proven the charge of murder beyond a reasonable doubt. The court found that the evidence did not meet the threshold required for conviction under this section.

What weighed in the mind of the Court?

The Supreme Court was primarily influenced by the lack of concrete evidence and the incomplete chain of circumstances. The court found it improbable that a mother would kill her newborn, especially given the family’s desire for a female child. The court also noted the unexplained delays in conducting the post-mortem and registering the crime, which raised doubts about the prosecution’s case.

Fact:Law Ratio

Logical Reasoning:

The court emphasized that while the post-mortem report indicated strangulation, the totality of evidence did not conclusively link the appellant to the crime. The court stated, “It is true that in the post-mortem, doctor has opined that death is due to asphyxia and there were marks of strangulation, but at the same time if totality of evidence on record is considered, motive is not established and it is totally unnatural for the appellant-mother to kill her own baby by strangulation.” The court also noted, “The Trial court as well as the High Court has based conviction on presumptions without any basis.” The court concluded, “From the totality of evidence on record it is clear that the baby girl was put in incubator with an oxygen mask and she has also not opened her eyes and she did not cry after birth. There was a possibility of natural death.”

The Supreme Court analyzed the evidence and determined that the prosecution had not established the necessary chain of circumstances to prove the appellant’s guilt beyond a reasonable doubt. The court found that the lower courts had relied on presumptions and failed to consider the possibility of natural death or other factors. The court also highlighted the lack of motive and the unexplained delays in the investigation.

Key Takeaways

• Convictions based on circumstantial evidence require a complete and unbroken chain of circumstances.
• Motive is a crucial element in proving guilt, especially in cases involving family members.
• Unexplained delays in investigation and post-mortem can raise doubts about the prosecution’s case.
• Courts must avoid relying on presumptions and ensure that guilt is proven beyond a reasonable doubt.

Directions

The Supreme Court set aside the judgments of the trial court and the High Court, acquitting the appellant of the charge framed against her. The appellant’s bail bonds were cancelled.

Development of Law

The ratio decidendi of this case is that a conviction based on circumstantial evidence must be supported by a complete chain of circumstances that rules out any reasonable doubt. This judgment reinforces the principle that the prosecution must prove its case beyond a reasonable doubt, especially in cases where the evidence is circumstantial.

Conclusion

The Supreme Court’s decision in Manju vs. State of Delhi underscores the importance of rigorous standards of proof in criminal cases, particularly when relying on circumstantial evidence. The court’s emphasis on the need for a complete chain of circumstances and the absence of a clear motive highlights the high burden placed on the prosecution to prove guilt beyond a reasonable doubt. The acquittal of Manju serves as a reminder that convictions should not be based on presumptions or incomplete evidence.