The Supreme Court of India, in a landmark judgment, upheld the conviction of Vijaya Singh and his mother, Basanti Devi, in a gruesome case of bride burning. The ruling, delivered by Justice Bela M. Trivedi and Justice Satish Chandra Sharma in Criminal Appeal No. 122 of 2013, reiterated that statements recorded by a Judicial Magistrate under Section 164 of the Criminal Procedure Code (CrPC) carry a greater presumption of reliability and cannot be easily retracted without compelling reasons. The Court’s decision affirms the evidentiary sanctity of such statements in ensuring justice, especially in cases hinging on circumstantial evidence.
Case Background
The case centered on the death of Devaki, who succumbed to 100% burn injuries on September 14, 2003, within just 17 months of her marriage to Vijaya Singh. The prosecution alleged that the deceased was subjected to harassment by her in-laws—Vijaya Singh and his mother, Basanti Devi—which culminated in her murder.
Shankar Singh, the deceased’s brother, lodged an FIR (No. 04/2003) at PS R.P. Jakholi, Rudraprayag, Uttarakhand, suspecting foul play after observing the condition of his sister’s body. Devaki’s body was found in her matrimonial home in a naked state, with green grass covering her remains—a detail that appeared to have been staged. The trial court and the High Court of Uttarakhand convicted the accused under Sections 302 (murder) and 201 (causing disappearance of evidence) of the Indian Penal Code (IPC), sentencing them to life imprisonment. The appellants challenged this verdict before the Supreme Court.
Key Legal Issues
- Reliability of Section 164 CrPC Statements
Central to the appeal was the reliability of statements recorded under Section 164 CrPC by two key witnesses: PW-3 and PW-4, the daughters of Basanti Devi and sisters of Vijaya Singh. While these witnesses later retracted their statements during the trial, the Supreme Court rejected their retraction, citing the safeguards inherent in judicially recorded statements.
The Court noted: “A statement under Section 164 CrPC serves a special purpose in criminal investigations, being recorded by a Judicial Magistrate and free from the constraints of statements recorded by police under Section 161 CrPC. Such statements are not lightly discarded.”
The Court further emphasized that the procedure ensures voluntary and truthful disclosure, and frivolous retractions would dilute the value of such statements. - Weight of Circumstantial Evidence
The case lacked eyewitness testimony and relied on circumstantial evidence. Drawing from the principles of circumstantial evidence laid down in Sharad Birdhichand Sarda v. State of Maharashtra, the Court reiterated that:
- The chain of evidence must be complete.
- The evidence must be consistent with the guilt of the accused and exclude any hypothesis of innocence.
- The Supreme Court agreed with the trial court and High Court findings that the circumstantial evidence overwhelmingly pointed to the guilt of the accused.
- Unnatural Conduct of the Accused
The Court found the behavior of Vijaya Singh and Basanti Devi after the incident to be highly suspicious. The appellants delayed informing the deceased’s family about her death, made no attempt to secure medical help, and manipulated the crime scene by placing grass over the body and sprinkling water on the burnt bedding.
The Court observed: “The conduct of the appellants, both before and after the incident, is inconsistent with that of innocent individuals. Their actions point to their complicity in the crime.” - Rejection of Defense Arguments
The defense argued that Devaki’s death was a case of suicide caused by frustration over her inability to join her husband, who worked in Chandigarh. The Court dismissed this theory, pointing out that the deceased was pregnant at the time and had recently shown hope of moving to Chandigarh with her husband. The theory lacked proportionality and plausibility.
Key Observations by the Supreme Court
The Court highlighted several critical points in its judgment:
- On Statements Under Section 164 CrPC:
“A judicially recorded statement carries greater weight and cannot be easily discarded based on unsubstantiated claims of duress or manipulation. Allowing retractions without strong reasons would negate the distinction between statements recorded by police and those by a Judicial Magistrate.”
- On Circumstantial Evidence:
“In the absence of direct evidence, the cumulative effect of proved circumstances must irresistibly point to the guilt of the accused. Here, the chain of evidence leaves no room for doubt.”
- On the Crime Scene and Post-Incident Conduct:
“The appellants’ manipulation of the crime scene and their failure to act in a manner consistent with innocence underscores their culpability.”
Decision of the Court
Dismissing the appeal, the Court upheld the conviction and life sentences of the accused, stating:
“The evidence, taken collectively, leaves no room for doubt regarding the appellants’ guilt. The statements recorded under Section 164 CrPC, corroborated by circumstantial evidence, form a consistent narrative pointing to their culpability.”
The appellants were directed to surrender within two weeks to serve their sentences.
