Absence of Ligature Mark on Neck Suggests Possibility of Suicide, Not Murder: Supreme Court Acquits Man Accused of Matricide

"Prosecution Must Prove Homicide Beyond Doubt Before Convicting for Murder Based Solely on Circumstantial Evidence," The Supreme Court of India, on October 7, 2025, acquitting a man who had been convicted of murdering his own mother. The Court found that the prosecution had failed to establish that the death was homicidal and observed that "in a case resting entirely on circumstantial evidence, any lingering doubt on the nature of death strikes at the foundation of the prosecution’s case." In reversing the conviction under Section 302 of the Indian Penal Code, the Court invoked the "five golden principles" laid down in Sharad Birdhichand Sarda, and held that they were not satisfied.

The two-judge bench of Justice K.V. Viswanathan and Justice K. Vinod Chandran set aside the concurrent findings of the Bombay High Court and the Sessions Court, which had sentenced the appellant to life imprisonment. The judgment underscores that mere suspicion or gaps filled by inferences cannot sustain a conviction for murder when material contradictions exist in medical evidence, witness testimonies, and the investigative process.

"Medical Expert Admitted That Injuries Were Consistent With Suicide by Hanging, Not Strangulation": Supreme Court Rejects Prosecution Theory of Homicide

The Supreme Court began its analysis by highlighting serious ambiguities in the medical evidence. Dr. Radhakishan Sarjerao Salunke, who conducted the postmortem, stated that the absence of ligature marks on the back of the neck could indicate death by hanging rather than strangulation. The prosecution had claimed that the appellant strangled his mother with a nylon rope, but the postmortem revealed otherwise.

The Court quoted PW-6's testimony, noting, “The absence of ligature mark on the back of neck is possible in case of hanging... In case of strangulation, ligature marks should be present all around the neck.” Furthermore, the doctor stated that imprint abrasions are more consistent with hanging, and added that the head injury on the deceased was not possible from the blunt iron pipe allegedly used, as the injury appeared to be caused by a sharp-edged object.

The bench concluded that “the medical evidence fails to conclusively establish that the death was homicidal. The possibility of suicide cannot be ruled out,” thereby eroding the very foundation of the murder charge.

"Where Chain of Circumstances Is Incomplete, Conviction Cannot Be Sustained": Supreme Court Cautions Against Stretching Inferences in Murder Cases

The Court reiterated that in cases based entirely on circumstantial evidence, the prosecution must satisfy the five-fold test established in Sharad Birdhichand Sarda. The Court emphasized that the circumstances must be fully established, must lead only to the guilt of the accused, must exclude every other possibility, must be conclusive, and must form an unbroken chain.

The bench warned that "the mind is apt to take a pleasure in adapting circumstances to one another, and even in straining them a little... to force them to form parts of one connected whole," quoting from Hanumant v. State of Madhya Pradesh. It held that this tendency is particularly dangerous in cases involving capital charges like murder and that courts must avoid drawing conclusions that the evidence cannot reliably support.

In this case, the Court found that the recovery of alleged weapons, the conduct of the accused, and the purported motive failed to meet the rigorous standard required to establish guilt. The Court observed, “None of the links in the chain of evidence are reliable; and even if accepted, they do not exclude all other hypotheses.

"Schizophrenia Document Ignored by Police Could Hold the Key": Supreme Court Faults Investigation, Allows Defence to Use Unexhibited Document

The Court was particularly critical of the police for failing to exhibit a medical certificate showing that the deceased had been diagnosed with schizophrenia in 1989. The certificate, though obtained by the Investigating Officer, was never marked or brought into formal evidence by the prosecution. However, the Court held that the defence is entitled to rely on such a document, even if not formally exhibited.

Quoting from Ramaiah alias Rama v. State of Karnataka, the Court said, “Even without formal proof thereto by the prosecution, it was always open for the defence to seek reliance on such an evidence to falsify the prosecution version.” The bench observed that the injuries sustained by the deceased could very well have been self-inflicted in a schizophrenic episode, and the failure to probe this possibility cast a further shadow on the theory of homicide.

"If Co-Accused Is Acquitted on Same Evidence, Conviction of Other Cannot Stand Without Independent Corroboration": Supreme Court Notes State Did Not Appeal Against Acquittal

The Supreme Court also noted that the co-accused, Balasaheb Gangadhar Gitte, had already been acquitted by the High Court based on the same set of evidence, particularly the recovery of the nylon rope. The State did not appeal this acquittal. The Court remarked, “Similar evidence relied upon to convict the appellant cannot be selectively accepted while rejecting it against the co-accused.”

This selective application of evidence further weakened the prosecution’s case, leading the Court to doubt the credibility of the entire recovery process.

"Failure to Investigate Mysterious Attempted Cremation Raises Doubts About Entire Case": Supreme Court Criticizes Laxity of Police

Another critical issue was the police's failure to properly investigate the attempted cremation of the deceased. Police officers, including the Deputy Superintendent of Police (PW-8), admitted that a crowd had gathered for the cremation, and that they had pulled the body off the pyre upon suspicion. However, none of the people present at the cremation site were identified or examined as witnesses.

The Court observed, “There is something more than what meets the eye in this case… why no further leads from that time, place and alleged event were picked up is inexplicable. It baffles one’s comprehension.”

This lapse, in the Court’s view, severely undercut the credibility of the prosecution’s narrative, especially since the appellant’s presence at the cremation site was not established, and he was not seen organising or participating in it until later in the day.

"Prosecution Witness Was Politically Connected to Appellant’s Uncle, Who Had Property Dispute with Deceased": Supreme Court Discards Evidence of Motive and Recovery

The Court found serious credibility issues with PW-3, the appellant’s uncle, who alleged that the appellant had a motive to kill his mother over property. The Court found that PW-3 himself had a long-standing property dispute with the deceased, had filed civil suits, and had even manipulated the recovery witness (PW-2) to support the prosecution’s case.

PW-2, who testified about the alleged recovery of an iron pipe and blood-stained clothes, admitted under cross-examination that he was close to PW-3, did not witness the actual recovery, and could not read the recovery panchnama he signed. The Court held that “to put it mildly, the witness has materially contradicted himself, and we have no doubt that he is taking enormous liberties with truth.”

The Court also noted that the DNA analysis was never conducted, the blood group of the deceased was not tested, and the FSL report was not put to the accused during his Section 313 examination, rendering this piece of evidence inadmissible.

In conclusion, the Court held that “the courts below have fallen into serious error in convicting the appellant on the basis of the evidence on record. The conviction disregards binding legal principles and misapplies the standards for circumstantial evidence.”

It allowed the appeal, set aside the conviction under Section 302 IPC, and acquitted the appellant of all charges, with the direction that his bail bonds stand discharged and he be released forthwith, if not required in any other case.

Date of Decision: October 7, 2025