The Supreme Court has upheld the murder conviction and life sentence of a man whose wife was throttled to death at their matrimonial home within nine months of marriage. The Court held that his failure to explain her death under Section 106 of the Evidence Act, together with a false defence, completed the chain of circumstantial evidence against him.
A Bench of Justice Sandeep Mehta and Justice Devendra Kumar Upadhyaya dismissed the appeals filed by the husband, Ramkishan Digambar Jadhav, and his brother Venkat. The Bench also affirmed their conviction for cruelty and dowry death under Sections 498-A and 304-B read with Section 34 of the IPC.
Background of the Case
Ramkishan married Vimalbai on 12th May, 1995. According to the prosecution, she was soon subjected to harassment and physical and mental torture over dowry demands for a television set, a tape deck, a plot in the MIDC area, and ₹50,000 in cash so that her husband could get employment.
On her visits to her parental home, she complained to her brother Narayan that she was being beaten and starved. On one occasion, she was tied with a rope and hung in a well with a threat that she would be killed if the demands were not met.
At about 1:00 a.m. on 1st February, 1996, Ramkishan went to Narayan’s house and said Vimalbai was having convulsions and was being taken to Naigaon for treatment. On the way, the family intercepted a bullock cart carrying her lifeless body, with blood oozing from her nostrils and fingers. Doctors at Naigaon Hospital declared her brought dead.
At 8:00 a.m. the same day, Ramkishan gave an application at Police Station Naigaon claiming that his wife suffered giddiness and lockjaw and died while they were having sexual intercourse. The post-mortem, however, recorded the cause of death as “asphyxia due to throttling”.
The trial Court at Biloli convicted Ramkishan, his father Digambar and brother Venkat under Sections 498-A and 304-B of the IPC, sentencing them to seven years’ rigorous imprisonment, but acquitted all accused of murder. On 3rd July, 2013, the Bombay High Court at Aurangabad dismissed the convicts’ appeal and partly allowed the State’s appeal, convicting Ramkishan of murder and sentencing him to life imprisonment with a fine of ₹5,000. Digambar died during the pendency of the appeal before the Supreme Court, and his appeal abated.
Arguments Before the Supreme Court
Counsel for the appellants argued that the case rested entirely on circumstantial evidence and that the chain of circumstances was incomplete. On behalf of Ramkishan, it was submitted that Vimalbai died accidentally after suffering a sudden epileptic seizure during intercourse. Counsel for Digambar and Venkat contended that they were roped in only because of their relationship with the husband, and sought acquittal on parity with the three female relatives who had been acquitted.
Counsel for the State of Maharashtra submitted that Vimalbai died a homicidal death while in her husband’s exclusive company, placing a heavy burden on him under Section 106 of the Evidence Act, which he failed to discharge. The State also relied on the statutory presumption under Section 113-B of the Evidence Act.
Supreme Court on Section 106 and False Defence
The Court noted that Dr. Shyam Nagapurkar (PW-1) found subcutaneous haemorrhage over the laryngeal area, bruises over the thyroid cartilages and a fracture of the left cornua of the hyoid bone. The doctor denied the epilepsy theory, noting there was no lock-jaw or displacement of the tongue and that the internal neck injuries could not be caused by an epileptic fit.
Holding that the burden rested heavily on the husband, the Court said he was required “to offer a cogent, credible, and satisfactory explanation regarding the circumstances culminating into her death.”
The Bench relied on Trimukh Maroti Kirkan v. State of Maharashtra, (2006) 10 SCC 681, where the Court had observed that “The inmates of the house cannot get away by simply keeping quiet and offering no explanation”.
The Court held that Ramkishan’s failure to discharge this burden, “coupled with the introduction of a false defence, provides an additional incriminating link that completes the chain of circumstantial evidence”, establishing his guilt for murder.
On the dowry death charge, the Court found the testimony of Narayan (PW-2) corroborated by the marriage mediator, Vimalbai’s father and two independent neighbours. It held that “the accused-appellants failed to rebut the statutory presumption under Section 113-B of the Evidence Act and were rightly convicted by the Courts below.”
Outcome
Finding no reason to interfere with the High Court’s judgment, the Supreme Court dismissed the appeals. It cancelled the appellants’ bail bonds and directed them to surrender before the trial Court within four weeks, failing which the trial Court shall take steps, including issuing non-bailable warrants, to secure their arrest.
Case Title: Ramkishan Digambar Jadhav v. The State of Maharashtra
Case No.: Criminal Appeal No. 1849 of 2013 with Criminal Appeal No. 962 of 2014
Bench: Justice Sandeep Mehta and Justice Devendra Kumar Upadhyaya
Date: November 2, 2026
