Supreme Court overturns conviction in strangulation case due to lack of conclusive evidence: Ravi vs. State of Punjab (2025) INSC 170 (10 February 2025)

Introduction

Date of the Judgment: 10 February 2025
Citation: 2025 INSC 170
Judges: Pankaj Mithal, J., Ahsanuddin Amanullah, J.

In a case hinging on circumstantial evidence, the Supreme Court of India addressed the critical question of whether the prosecution had sufficiently proven the guilt of the accused, Ravi, beyond a reasonable doubt in the alleged murder of his wife. Ravi was convicted by lower courts for the murder of his first wife, Jamni, by strangulation. The Supreme Court, after reviewing the evidence, had to determine if the conviction was justified or if the benefit of the doubt should be extended to the accused.

The bench comprised Justice Pankaj Mithal and Justice Ahsanuddin Amanullah, who delivered the judgment.

Case Background

The appellant, Ravi, resided in village Madh, Amritsar, in a jhuggi (hut) on open land, working as a laborer. He lived with his deceased wife, Jamni, his second wife, Soma, and his two sons from his first marriage. They had been living together for approximately 10-12 years.

The incident occurred on 22.08.2014. According to the prosecution, Chaina Ram (PW-1), the brother of the deceased, lodged a Zero FIR at Police Station Rajgarh, District Churu, Rajasthan, on the same day. He stated that his sister, Jamni, lived with her husband, Ravi, in Rayya Mandi, Tehsil Baba Bakala, District Amritsar, Punjab. He alleged that on the night of 22.08.2014, around 11:00 pm, Jamni was murdered by her husband in collusion with his second wife, Soma. The FIR further stated that Ravi transported the dead body from Rayya Mandi to village Gujjuwas in a truck. Chaina Ram also mentioned that his sister, Rajo, who resided in a neighboring jhuggi, witnessed Ravi strangling Jamni with a rope and was threatened not to disclose the incident to anyone.

The FIR was then transferred to Police Station Khilchian, Amritsar, Punjab, where the panchnama (record of observations) was executed, and a post-mortem was conducted on the deceased.

The panchnama indicated that it was conducted at village Rayya Mandi, Police Station Rayya, Tehsil Baba Bakala, District Amritsar, Punjab, where Ravi lived. The report recorded injury marks on the deceased’s body, including ligature marks around the neck and an open mouth with the tongue protruding outward.

The post-mortem report stated that the cause of death was asphyxia due to hanging, with ligature marks on the neck.

Timeline

Course of Proceedings

The prosecution presented its case by examining seven witnesses, including Chaina Ram (PW-1), the brother of the deceased; Rajo (PW-2), her sister; Deep Chand (PW-3), her cousin; Dr. Mohan Lal Meena (PW-5), who conducted the post-mortem; retired DSP Bagla Ram (PW-6); Inspector Rachhpal Singh (PW-4); and Inspector Amolak Singh (PW-7).

The case was primarily based on circumstantial evidence. Rajo (PW-2), the sister of the deceased, was initially considered an eyewitness but had not directly witnessed the crime. She resided in a neighboring jhuggi and purportedly had firsthand information.

After the death of Jamni, Ravi transported her body to the native place of Chaina Ram (PW-1) and Rajo (PW-2), accompanied by Rajo herself.

Chaina Ram (PW-1), who had lodged the initial complaint, testified that his sister was married to Ravi and resided in Rayya Mandi. However, he claimed to be unaware of the events of 22.08.2014, stating that his sister died due to illness and that Ravi was not responsible for her death. Consequently, he was declared a hostile witness.

Chaina Ram admitted to signing the Zero FIR (Exh. PW4/1) but claimed he signed a blank paper without knowing its contents. The Zero FIR was computerized and only bore his signatures.

Rajo (PW-2) was also declared hostile, stating that there were no disputes between her sister and Ravi and that Jamni died due to illness and breathing problems. Similarly, Deep Chand (PW-3) expressed ignorance about the events of 22.08.2014 and was declared hostile.

With the primary witnesses turning hostile, the prosecution relied on formal witnesses, including Dr. Mohan Lal Meena (PW-5), retired DSP Bagla Ram (PW-6), SHO/retired Inspector Racchpal Singh (PW-4), and Inspector Amolak Singh (PW-7).

Legal Framework

The legal framework relevant to this case primarily involves the principles governing circumstantial evidence and the burden of proof in criminal trials, particularly concerning Section 106 of the Evidence Act, 1872.

Section 106 of the Evidence Act states:

“When any fact is especially within the knowledge of any person, the burden of proving that fact is upon him.”

This provision stipulates that if a fact is particularly within the knowledge of a person, the burden of proving that fact lies with them. In the context of this case, the prosecution argued that since the death occurred within the confines of the appellant’s residence, the burden was on him to explain the circumstances of the death.

Arguments

Arguments by the State:

• The State, relying on Trimukh Maroti Kirkan v. State of Maharashtra [(2006) 10 SCC 681], argued that Section 106 of the Evidence Act places a burden on the inmates of the house to provide a cogent explanation regarding the commission of the crime.
• The prosecution contended that since the crime occurred within the four walls of the jhuggi, and the appellant was present, the burden was on him to explain the circumstances under which the deceased died.

Arguments by the Appellant:

• The appellant argued that the prosecution failed to establish his guilt beyond a reasonable doubt based on the circumstantial evidence presented.
• The appellant’s counsel emphasized that the initial burden lies with the prosecution to establish a prima facie case before the burden shifts to the accused under Section 106 of the Evidence Act.
• The appellant, in his statement under Section 313 of the Code of Criminal Procedure, stated that the deceased died a natural death due to chronic tuberculosis, for which she was undergoing treatment at Beas hospital.

Innovativeness of the argument:

The innovativeness in the appellant’s argument lies in invoking his statement recorded under Section 313 of the Code of Criminal Procedure to highlight the deceased’s medical condition, which the prosecution failed to investigate further. This pointed out a critical gap in the prosecution’s case, undermining the claim of murder.

Issues Framed by the Supreme Court

1. Whether the prosecution had produced sufficient evidence to prove the guilt of the appellant beyond a reasonable doubt based on circumstantial evidence.
2. Whether the principles of Section 106 of the Evidence Act were correctly applied, considering the initial burden on the prosecution to establish a prima facie case.

Treatment of the Issue by the Court

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

Authorities

The Supreme Court considered the following authorities:

1. Sharad Birdhichand Sarda v. State of Maharashtra [(1984) 4 SCC 116]: This case laid down the five golden principles (panchsheels) of circumstantial evidence.
2. Trimukh Maroti Kirkan v. State of Maharashtra [(2006) 10 SCC 681]: This case pertains to the application of Section 106 of the Evidence Act.
3. Anees v. The State Govt. of NCT [(2024) SCC OnLine SC 757]: This case elaborately considered the principles of law governing the applicability of Section 106 of the Evidence Act.
4. Section 313 of Code of Criminal Procedure: This section pertains to the examination of the accused.
5. Section 106 of the Evidence Act, 1872:“When any fact is especially within the knowledge of any person, the burden of proving that fact is upon him.”

Judgment

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

How each authority was viewed by the Court?

• Sharad Birdhichand Sarda v. State of Maharashtra [(1984) 4 SCC 116]: The Court applied the principles outlined in this case to evaluate the circumstantial evidence, finding it insufficient to conclusively establish guilt.
• Trimukh Maroti Kirkan v. State of Maharashtra [(2006) 10 SCC 681]: The Court distinguished this case, clarifying that Section 106 of the Evidence Act does not absolve the prosecution of its initial burden to prove the offence.
• Anees v. The State Govt. of NCT [(2024) SCC OnLine SC 757]: The Court relied on this case to emphasize that Section 106 of the Evidence Act applies only after the prosecution has succeeded in proving facts from which a reasonable inference of guilt can be drawn.

What weighed in the mind of the Court?

The Supreme Court’s decision to overturn the conviction was primarily influenced by the following factors:

• Failure of the prosecution to establish guilt beyond a reasonable doubt based on circumstantial evidence.
• The benefit of doubt had to be given in favour of the appellant.
• The prosecution’s failure to investigate the appellant’s statement regarding the deceased’s chronic tuberculosis.
• The misapplication of Section 106 of the Evidence Act by the courts below, which overlooked the initial burden on the prosecution.

Fact:Law Ratio

Logical Reasoning:

ISSUE: Whether the prosecution had produced sufficient evidence to prove the guilt of the appellant beyond a reasonable doubt based on circumstantial evidence.

The Court’s reasoning was based on the principle that the prosecution must first establish a prima facie case before the burden shifts to the accused under Section 106 of the Evidence Act. The Court found that the prosecution failed to discharge this initial burden, and the circumstantial evidence was not conclusive enough to establish guilt beyond a reasonable doubt.

The Court also considered the appellant’s statement under Section 313 CrPC regarding the deceased’s illness, which the prosecution failed to investigate. This failure further weakened the prosecution’s case.

“In view of the totality of the facts and circumstances of this case, we are of the opinion that the prosecution has completely failed to produce evidence to prove the guilt of the appellant beyond the shadow of doubt on the basis of the circumstantial evidence.”

“Rather the evidence on record gives ample leverage for two conflicting opinions, and in such circumstances, the benefit of doubt has to be given in favour of the appellant.”

“Accordingly, the impugned judgment and order dated 23.01.2019 passed by the High Court of Punjab and Haryana at Chandigarh is liable to be and hereby set aside and the appeal deserves to be allowed.”

Key Takeaways

• The prosecution must establish a prima facie case before the burden shifts to the accused under Section 106 of the Evidence Act.
• Circumstantial evidence must be conclusive and exclude every possible hypothesis except the guilt of the accused.
• The benefit of doubt must be given to the accused if the evidence gives room for conflicting opinions.

Development of Law

The ratio decidendi of this case is that the prosecution must first establish a prima facie case before the burden shifts to the accused under Section 106 of the Evidence Act. The court reiterated that circumstantial evidence must be conclusive and exclude every possible hypothesis except the guilt of the accused. This reaffirms the importance of the prosecution’s initial burden in criminal trials and clarifies the application of Section 106 of the Evidence Act.

Conclusion

The Supreme Court allowed the appeal, setting aside the High Court’s judgment and order. The Court held that the prosecution failed to prove the guilt of the appellant beyond a reasonable doubt based on circumstantial evidence. The appellant was directed to be released from custody immediately.

Category:

Parent category: Criminal Law

Child categories:

• Circumstantial Evidence
• Burden of Proof
• Section 106, Evidence Act, 1872
• Section 313, Code of Criminal Procedure

FAQ

1. What is the main takeaway from the Ravi vs. State of Punjab case?
   The main takeaway is that the prosecution must first establish a prima facie case before the burden shifts to the accused under Section 106 of the Evidence Act. Circumstantial evidence must be conclusive and exclude every possible hypothesis except the guilt of the accused.
2. How does this case affect criminal trials in India?
   This case reaffirms the importance of the prosecution’s initial burden in criminal trials and clarifies the application of Section 106 of the Evidence Act. It emphasizes that the prosecution cannot rely on Section 106 to make up for deficiencies in their evidence.
3. What is Section 106 of the Evidence Act?
   Section 106 of the Evidence Act states, “When any fact is especially within the knowledge of any person, the burden of proving that fact is upon him.” However, this section only applies after the prosecution has established a prima facie case.