A complete circumstantial chain, corroborated by medical and forensic evidence, sustains a murder conviction.

On 9 January 2018, the deceased was found unconscious at home.

The appellant, a friend of her husband, called the husband to return home and later said that she had hanged herself. She was taken to hospital, where she was declared dead.

The prosecution alleged that the appellant struck the deceased with scissors and strangled her, then presented the death as suicide.

The Sessions Court convicted him under Sections 302, 201 and 203 of the IPC and imposed life imprisonment for murder, with additional sentences for the other offences.

The appellant appealed, challenging, among other matters, the proof of homicidal death and the completeness of the circumstantial chain.

Whether the prosecution proved beyond reasonable doubt that the deceased died by homicidal strangulation, rather than suicide by hanging.

Whether the circumstantial evidence formed a complete chain establishing the appellant’s guilt for murder and the offences under Sections 201 and 203 of the IPC.

The Court applied Sections 302, 201 and 203 of the IPC, concerning murder, causing disappearance of evidence and giving false information about an offence.

It applied the circumstantial-evidence principles in Hanumant Govind Nagundkar v. State of Madhya Pradesh, AIR 1952 SC 343, and Sharad Birdhichand Sarda v. State of Maharashtra, (1984) 4 SCC 116: each circumstance must be fully established, consistent only with guilt, and together form a complete chain excluding reasonable hypotheses of innocence.

Under Section 106 of the Evidence Act, an accused may be expected to explain facts especially within their knowledge only after the prosecution has established facts supporting a reasonable inference of guilt; that provision does not relieve the prosecution of its burden.

The Court also considered the medical distinction between hanging and strangulation in Javed Abdul Rajjaq Shaikh v. State of Maharashtra, (2019) 10 SCC 778, and held, relying on Ponnusamy v. State of Tamil Nadu, (2008) 5 SCC 587, that the absence of a hyoid fracture does not exclude strangulation.

It further referred to Section 118 of the Evidence Act on witness competency and the principles concerning child witnesses in Rajkumar v. State of M.P., (2014) 5 SCC 353.

The Court held that the electronic call-detail record could not be read without the certificate required by Section 65B(4) of the Evidence Act.

The Court found that the medical evidence—particularly the doctor’s opinion that death resulted from external pressure blocking the airway, together with the neck findings and head injury—supported homicidal strangulation.

It also relied on the FSL scene inspection, which found no signs that the ceiling fan had been used for hanging, and rejected suicide by hanging as a reasonable alternative.

The appellant’s presence at the house was supported by the husband’s evidence, the testimony of PW9 and PW10 that they saw him heading towards the society, and the surrounding evidence about his movements and subsequent conduct.

The Court treated the appellant’s failure to explain how he found and brought down the deceased, while advancing the hanging account, as relevant in light of the established circumstances—not as a substitute for the prosecution’s burden.

It considered the discrepancies concerning the forehead injury and the postmortem record, but held they did not undermine the combined medical and testimonial evidence.

The absence of motive evidence and the non-examination of the daughter were likewise not decisive on the record.

It found no basis to interfere with the convictions or sentences under Sections 302, 201 and 203 of the IPC, dismissed the appeal and upheld the Sessions Court’s judgment.

The application for suspension of sentence was disposed of as no longer surviving.