Supreme Court Upholds Conviction in Dowry Death Case: Vijaya Singh vs. State of Uttarakhand (2024)

Date of the Judgment: 25 November 2024

Citation: 2024 INSC 905

Judges: Bela M. Trivedi, J., Satish Chandra Sharma, J.

Can a conviction be upheld solely on the basis of circumstantial evidence? The Supreme Court of India recently addressed this question in a case involving the death of a young woman at her in-laws’ house. The court examined whether the chain of circumstances was complete enough to unequivocally point to the guilt of the accused, her husband and mother-in-law, for her murder. The judgment was delivered by a two-judge bench comprising Justice Bela M. Trivedi and Justice Satish Chandra Sharma, with the majority opinion authored by Justice Satish Chandra Sharma.

Case Background

Devaki married Vijaya Singh in April 2002. On September 14, 2003, more than a year after the wedding, Devaki died an unnatural death at her in-laws’ house. The prosecution alleged that Vijaya Singh and his mother, Basanti Devi, murdered her. An FIR was filed by Devaki’s brother, Shankar Singh, who suspected foul play after receiving a phone call from the in-laws stating that Devaki had set herself ablaze. Shankar Singh, upon reaching the scene, found Devaki’s body in a near-naked state with green grass placed over it, leading him to believe she was murdered rather than having committed suicide.

Timeline:

Course of Proceedings

The Trial Court convicted Vijaya Singh and Basanti Devi under Section 302 (murder) and Section 201 (causing disappearance of evidence of offence) of the Indian Penal Code, 1860. The High Court of Uttarakhand upheld the Trial Court’s decision, finding no infirmity in the analysis of evidence. The appellants then appealed to the Supreme Court.

Legal Framework

The case primarily revolves around the application of circumstantial evidence in criminal cases. The Supreme Court referred to the principles laid down in Sharad Birdhichand Sarda v. State of Maharashtra [(1984) 4 SCC 116], which outlines the conditions for establishing guilt based on circumstantial evidence. These conditions are:

• ✓ The circumstances from which the conclusion of guilt is drawn must be fully established.
• ✓ The facts so established should be consistent only with the hypothesis of the guilt of the accused.
• ✓ The circumstances should be of a conclusive nature and tendency.
• ✓ They should exclude every possible hypothesis except the one to be proved.
• ✓ There must be a chain of evidence so complete as not to leave any reasonable ground for a conclusion consistent with the innocence of the accused.

The Court also discussed the relevance of statements recorded under Section 164 of the Code of Criminal Procedure, 1973, clarifying that while not substantive evidence, they can be used for corroboration and contradiction as per Section 157 of the Indian Evidence Act, 1872. The court noted that a statement under Section 164 CrPC is recorded by a Judicial Magistrate, which gives it more credibility than a statement recorded by a police officer under Section 161 of the CrPC.

Arguments

Appellants’ Arguments:

• ✓ There was a delay of 24 hours in registering the FIR, leading to fabrication of the story.
• ✓ There were contradictions in the testimonies of prosecution witnesses (PW-1, PW-2, PW-5, and PW-6).
• ✓ PW-1 was a distant relative and did not have direct knowledge of any cruelty or harassment.
• ✓ PW-1 and PW-5 gave contradictory statements regarding injuries on the deceased.
• ✓ Statements of PW-3 and PW-4 recorded under Section 164 CrPC were not voluntary and were recorded under threat.
• ✓ The medical evidence was flawed, as the doctor initially could not definitively state whether the death was homicidal or suicidal.
• ✓ The Trial Court and High Court failed to objectively analyze the circumstances, relying more on conjectures than evidence.
• ✓ The deceased committed suicide due to frustration of not going to Chandigarh.

Respondent’s Arguments:

• ✓ The circumstances of the case proved the guilt of the appellants beyond reasonable doubt.
• ✓ The chain of circumstances was complete and met the parameters for circumstantial evidence.
• ✓ In bride burning cases, the absence of cries from the victim suggests it was not a suicide, relying on Prabhudayal and Ors. v. State of Maharashtra [(1993) 3 SCC 573].
• ✓ The false plea of alibi taken by appellant no. 2 was an additional circumstance against the accused.

Submissions Table:

Issues Framed by the Supreme Court

The main issue before the Supreme Court was:

1. Whether the findings arrived at by the High Court are based on a correct appreciation of the evidence on record and are sustainable in the eyes of law.

The Supreme Court also dealt with the sub-issue of whether the death was suicidal or homicidal.

Treatment of the Issue by the Court:

Authorities

Cases Relied Upon:

• ✓ Sharad Birdhichand Sarda v. State of Maharashtra [(1984) 4 SCC 116] – Outlined the principles for evaluating circumstantial evidence.
• ✓ Prabhudayal and Ors. v. State of Maharashtra [(1993) 3 SCC 573] – Absence of cries in bride burning cases indicates homicide.
• ✓ R. Shaji v. State of Kerala [MANU/SC/0087/2013] – Discussed the two-fold objective of a statement under Section 164 CrPC.

Legal Provisions Considered:

• ✓ Section 302 of the Indian Penal Code, 1860 – Punishment for murder.
• ✓ Section 201 of the Indian Penal Code, 1860 – Causing disappearance of evidence of offence.
• ✓ Section 164 of the Code of Criminal Procedure, 1973 – Recording of confessions and statements.
• ✓ Section 157 of the Indian Evidence Act, 1872 – Former statements of witness may be proved to corroborate later testimony.

Authority Analysis Table:

Judgment

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

How each authority was viewed by the Court?

The Supreme Court relied on Sharad Birdhichand Sarda v. State of Maharashtra [(1984) 4 SCC 116]* to establish the principles governing circumstantial evidence, emphasizing that the circumstances must unequivocally point to the guilt of the accused. The Court followed Prabhudayal and Ors. v. State of Maharashtra [(1993) 3 SCC 573]* to support the inference that the absence of cries from the victim in a bride burning case suggests homicide rather than suicide. Additionally, the Court referred to R. Shaji v. State of Kerala [MANU/SC/0087/2013]* to clarify the evidentiary value of statements recorded under Section 164 of the Code of Criminal Procedure, 1973, noting that they can be used for both corroboration and contradiction.

What weighed in the mind of the Court?

The Supreme Court’s decision was heavily influenced by the following factors:

• ✓ Completeness of Circumstantial Evidence: The court found that the chain of circumstances was complete and pointed unequivocally to the guilt of the appellants.
• ✓ Inconsistency with Suicide Theory: The court found the suicide theory implausible, noting the lack of a strong motive, the pregnancy of the deceased, and the unnatural circumstances of the death.
• ✓ Credibility of Witnesses: The court gave weight to the statements of PW-3 and PW-4 recorded under Section 164 CrPC, despite their retraction in court, considering the circumstances under which the statements were recorded.
• ✓ Medical Evidence: The court relied on the medical expert’s opinion that 100% burn injuries are uncommon in suicide cases, supporting the conclusion of homicide.
• ✓ Conduct of the Accused: The court noted the unnatural conduct of the accused after the incident, including their failure to seek medical assistance and their tampering with the crime scene.
• ✓ False Plea of Alibi: The court considered the false alibi of appellant no. 2 as an additional circumstance against the accused.
• ✓ Presence of Injuries on the Accused: The court noted the fresh injury marks on the faces of the accused at the time of their arrest, which they could not adequately explain.

Sentiment Analysis of Reasons Given by the Supreme Court:

Fact:Law Ratio

Logical Reasoning:

Judgment

The Supreme Court upheld the conviction of Vijaya Singh and Basanti Devi, affirming the decisions of the Trial Court and the High Court. The Court found that the circumstantial evidence presented by the prosecution was strong and consistent, leaving no reasonable doubt about the guilt of the accused. The Court emphasized that the chain of circumstances was complete and pointed unequivocally to the appellants’ involvement in the murder of Devaki. The Court rejected the appellants’ arguments, including the claim that the death was a suicide, and found the evidence of tampering with the crime scene and the false alibi of appellant no. 2 to be incriminating. The Court also noted the presence of fresh injuries on the accused at the time of their arrest, which they could not adequately explain.

The Court quoted the following from the judgment:

“The principles governing the appreciation of circumstantial have been laid down by this Court in unequivocal terms in Sharad Birdhichand Sarda v. State of Maharashtra.”

“A statement under Section 164 CrPC serves a special purpose in a criminal investigation as a greater amount of credibility is attached to it for being recorded by a Judicial Magistrate and not by the Investigating Officer.”

“Once the entire evidence led by the prosecution is examined collectively and comprehensively, the only possibility that emerges is of the guilt of the appellants.”

The Court stated that “In the absence of a finding of illegality or perversity or impossibility of the impugned findings, consistent views taken by two courts cannot be disturbed on mere conjectures or surmises.”

Key Takeaways

• ✓ Convictions can be based on circumstantial evidence if the chain of circumstances is complete and points unequivocally to the guilt of the accused.
• ✓ Statements recorded under Section 164 of the Code of Criminal Procedure, 1973, are credible and can be used for corroboration, even if the witness retracts them later.
• ✓ Medical evidence plays a crucial role in determining the nature of death, especially in cases of burn injuries.
• ✓ The conduct of the accused, both before and after the incident, is important in assessing their guilt.
• ✓ False pleas of alibi can be used as additional evidence against the accused.

Directions

The Supreme Court directed that the appellants, if enlarged on bail, shall surrender before the concerned Jail Superintendent within two weeks from the date of the judgment for serving their sentence.

Development of Law

The ratio decidendi of this case is that a conviction can be based on circumstantial evidence if the chain of circumstances is complete and points unequivocally to the guilt of the accused. The judgment reinforces the principles laid down in Sharad Birdhichand Sarda v. State of Maharashtra [(1984) 4 SCC 116] and clarifies the evidentiary value of statements recorded under Section 164 of the Code of Criminal Procedure, 1973. There is no change in the previous positions of law, but the judgment reiterates the importance of a thorough and objective analysis of circumstantial evidence in criminal cases.

Conclusion

The Supreme Court dismissed the appeal, upholding the conviction of Vijaya Singh and Basanti Devi for the murder of Devaki. The Court’s decision emphasizes the importance of circumstantial evidence in criminal cases and the need for a thorough analysis of all the facts and circumstances to determine guilt beyond a reasonable doubt. The judgment underscores that the courts must consider all aspects of the case, including witness testimonies, medical evidence, and the conduct of the accused, to arrive at a just and fair conclusion.