The Supreme Court of India, in a landmark judgment, upheld the conviction and life sentences of Vijaya Singh and Basanti Devi in the tragic bride burning case of Devaki. The court emphasized that in cases based on circumstantial evidence, guilt must be proven beyond a shadow of doubt, observing, “The mental distance between ‘may be’ and ‘must be’ divides vague conjectures from sure conclusions.”
The judgment, delivered by Justice Bela M. Trivedi and Justice Satish Chandra Sharma, highlighted the essential principles governing circumstantial evidence and reaffirmed the convictions imposed by both the Trial Court and the Uttarakhand High Court.
Background of the Case
Devaki, a young woman married to Vijaya Singh in April 2002, died under suspicious circumstances on September 14, 2003, at her in-laws’ home in Rudraprayag, Uttarakhand. She was reportedly found with 100% burn injuries, with allegations of dowry-related harassment and family disputes preceding her death. Her brother, Shankar Singh, filed an FIR (No. 04/2003) alleging that Devaki’s death was not a suicide, as claimed by the accused, but a brutal murder orchestrated by her husband and mother-in-law.
The Trial Court convicted the two accused under Sections 302 (murder) and 201 (causing disappearance of evidence) of the Indian Penal Code, sentencing them to life imprisonment. The Uttarakhand High Court upheld the verdict, prompting the appellants to approach the Supreme Court.
Legal Issues Addressed
1. Reliability of Circumstantial Evidence:
The Supreme Court underscored the principles laid down in Sharad Birdhichand Sarda v. State of Maharashtra for cases reliant on circumstantial evidence. It held that the chain of circumstances must be complete, pointing unequivocally to the guilt of the accused while excluding every other reasonable hypothesis.
2. Delay in FIR Registration:
The appellants argued that the FIR’s registration was delayed by 24 hours, suggesting fabrication. The Court dismissed this contention, stating that the delay was reasonable given the nature of the incident and the family’s need to process the tragic death.
3. Credibility of Witness Statements:
Testimonies of the victim’s family and statements recorded under Section 164 of the CrPC were key. The Court noted that although two witnesses, sisters of the accused, retracted their earlier statements, their initial accounts corroborated the prosecution’s case. It also dismissed claims of coercion during the recording of these statements.
4. Expert Testimony on 100% Burns:
The defense argued that 100% burn injuries were possible in suicide cases, challenging the testimony of the medical expert. However, the Court found that the doctor’s opinion—stating that such injuries are uncommon in self-inflicted burns—aligned with other evidence pointing to homicide.
Key Observations by the Court
The Supreme Court emphasized that circumstantial evidence must establish guilt with certainty, noting:
“The facts so established should be consistent only with the hypothesis of guilt and exclude every other hypothesis except that the accused is guilty.”
The Court also highlighted the incriminating behavior of the accused, including their failure to seek timely medical assistance and attempts to manipulate the crime scene.
It further rejected the plea of alibi by Basanti Devi, observing that her claim of being away at a flour mill during the incident was unsubstantiated and contradicted by witness accounts.
Judgment
Dismissing the appeal, the Court ruled that the cumulative weight of the evidence left no room for doubt about the appellants’ guilt. It upheld the life sentences, stating that the findings of the lower courts were sound and legally sustainable.
