In a significant judgment, the Supreme Court of India confirmed the conviction of three individuals in the murder case of Rajalakshmi, overturning the earlier acquittal by the trial court. The bench, comprising Justice Bela M. Trivedi and Justice Satish Chandra Sharma, emphasized that the complete chain of circumstances in the case conclusively pointed towards the guilt of the accused. The court’s decision came while hearing Uma & Anr. vs. State, Criminal Appeal Nos. 757 of 2015 and 67 of 2016.
Case Background
Rajalakshmi was married to Ravi (Accused No. 2) on February 10, 2008, in Vilathikulam, Tamil Nadu. Her death occurred under suspicious circumstances on August 23, 2008, barely six months after her wedding. Initially reported as a suicide by paint ingestion, an autopsy revealed signs of strangulation, indicating a homicidal death.
The deceased’s adoptive father, Chandrakasan (PW-1), had reported to the police that Rajalakshmi faced consistent harassment from her husband and his aunt, Uma (Accused No. 1). He also alleged that Ravi had an illicit relationship with Uma, which fueled tensions between him and Rajalakshmi. Further allegations suggested that the accused poured kerosene and paint into Rajalakshmi’s mouth to disguise the murder as a suicide.
Legal Issues and Proceedings
The primary issues before the court were whether the trial court’s acquittal of the accused was correct and whether the prosecution had established a complete chain of circumstances implicating the accused beyond reasonable doubt. The trial court initially acquitted all three accused, citing insufficient direct evidence and a failure to establish motive convincingly. However, the High Court reversed this decision, finding enough circumstantial evidence that linked the accused to the crime, prompting the present appeal before the Supreme Court.
Supreme Court’s Observations
The Supreme Court scrutinized the evidence, including testimonies of witnesses (P.W.-1 to P.W.-4), medical reports, and the accused’s behaviour before and after the incident. The court highlighted five critical factors that formed the chain of circumstances:
1. Motive: The prosecution argued that Ravi and Uma had an illicit relationship, which had become a significant source of conflict with Rajalakshmi.
2. Presence at the Scene: The accused were present at the home when Rajalakshmi died, which the defence could not refute with a credible alibi.
3. Medical Evidence: The autopsy revealed multiple ante-mortem injuries and a fractured hyoid bone, indicating strangulation. The court noted that these injuries were inconsistent with the alleged suicide by paint ingestion.
4. Inconsistent Defence: In their statements under Section 313 CrPC, the accused provided explanations that the court found implausible and inconsistent with the evidence.
5. Conduct of the Accused: The court emphasized that the accused neither informed the victim’s family of her death nor offered any convincing explanation for the circumstances leading to it, further strengthening the inference of guilt.
The bench underscored that in cases where direct evidence is lacking, a conclusive chain of circumstances can suffice to establish guilt. Citing its earlier ruling in Trimukh Maroti Kirkan v. State of Maharashtra, the court stated, “When an offence takes place within the privacy of a house, the burden of explaining the incident shifts to the accused.” In this case, the accused failed to offer a satisfactory explanation, making the prosecution’s case robust.
Key Judgments Cited
The Supreme Court reiterated the principles set out in Sharad Birdhichand Sarda v. State of Maharashtra (1984), stating that circumstantial evidence must be consistent only with the guilt of the accused, ruling out any hypothesis of innocence. It noted that the prosecution had presented a consistent chain of evidence that left no reasonable doubt regarding the culpability of the accused.
Upholding the High Court’s conviction, the Supreme Court dismissed the appeals filed by Uma, Ravi, and Balasubramanian. The court confirmed the sentences of life imprisonment under Sections 302 (murder), 120B (criminal conspiracy), and other relevant provisions of the Indian Penal Code.
