No Evidence, No Motive, Not Even Proof of Murder: Supreme Court Slams Conviction, Acquits Man Accused of Killing Wife After Two Years of Marriage

“We do not find a single circumstance pointing to the guilt of the accused… the chain of circumstances must not only point to guilt but must exclude every other hypothesis except guilt.” - In a major reversal of a conviction under Section 302 IPC, the Supreme Court on April 7, 2025, acquitted Jagdish Gond, a man who was sentenced to life imprisonment for the alleged murder of his wife. The Court held that the prosecution failed to prove whether the death was even homicidal, let alone that the husband was the perpetrator.

Bench of Justices K. Vinod Chandran and Sudhanshu Dhulia came down heavily on the Chhattisgarh High Court for overturning a well-reasoned acquittal by the Trial Court, based solely on a disbelieved alibi and the fact that the couple resided together.

“Where two views are possible, the one taken by the Trial Court to acquit the accused, if found to be a plausible one, cannot be upset lightly… The presumption of innocence available to an accused gets further fortified by the acquittal entered by the Trial Court.”

“Not Even the Doctor Could Say It Was Murder – Medical Evidence Was Inconclusive, Alibi Ignored, and Witnesses Contradicted Themselves,” Says Apex Court

The case involved the tragic death of a young woman on January 29, 2017, just two years into her marriage. Her husband claimed to have found her lying motionless on the cot after returning home from his night shift at a cement factory. A ligature mark was found on the front side of the neck, but no noose, no other injuries, and no clear cause of death were found.

Postmortem records, inquest reports, and the doctor’s deposition revealed that the cause of death was asphyxia due to compression of the trachea, but the forensic query regarding whether the death was suicidal or homicidal remained unanswered.

“The mark found on the body of the deceased is caused by noose… mark of throttling has not been found… So, the death of deceased was homicidal or suicidal is the subject of investigation,” the doctor stated.

The Court found it “highly improper” that the High Court convicted the accused in such circumstances, especially when even the first intimation of unnatural death came from the husband himself, and no suspicion was raised by the deceased's family until five days later.

“Section 106 Evidence Act Does Not Mean Accused Must Prove Innocence — Police Should Have Investigated the Alibi, Not Shifted Burden on the Accused,” Rules Court

The High Court had relied heavily on Section 106 of the Indian Evidence Act, holding that since the couple lived together, the accused must explain how his wife died. The Supreme Court strongly disagreed.

“The High Court unfortunately reversed the acquittal without anything other than a finding on alibi not having been proved… The explanation that he was at work was not an afterthought but part of the initial police statement. The police ought to have verified it.”

It added that Section 106 cannot be invoked when the prosecution hasn’t even proven that a crime was committed, stating that the failure of the accused to explain a death, without clear proof of murder, is not enough for conviction.

“There Was No Cruelty, No Harassment, No Motive – Only Vague Complaints of Laziness and Illness. This Cannot Sustain Charges Under Section 498A or 306 Either”

The Court also examined whether the husband could be convicted for abetment of suicide or cruelty under Section 498A IPC, as alleged by the deceased’s family. But witnesses, including the deceased’s own parents and cousin, could only recall that her in-laws occasionally complained she was “lazy” or “unwell”.

“There is absolutely no allegation of physical violence. Nor were there any ante mortem injuries. Not a single circumstance emerged from evidence that could even remotely prove guilt.”

The Court called the prosecution’s case “speculative at best” and warned that such serious charges cannot be sustained without specific, credible, and corroborated evidence.

“True, a young woman died tragically. But criminal law does not allow courts to convict merely because the death occurred in a matrimonial home.”

Setting aside the High Court’s judgment, the Supreme Court held that no case had been made out either under Section 302, or under Sections 498A or 306 IPC, and ordered the immediate release of the accused.

The Supreme Court concluded: “Having found absolutely no circumstance leading to the guilt of the accused, we are unable to sustain the order of the High Court, which we set aside. The order of acquittal of the Trial Court stands restored. The accused shall be set free forthwith, if not wanted in any other case. Any bail bonds executed shall stand discharged.”

Date of decision : April 7, 2025