A husband’s failure to explain his wife’s homicidal death in their home reinforced the complete circumstantial chain.

The appellant was convicted under Section 302 IPC for the murder of his wife and sentenced to life imprisonment and a fine.

The prosecution case was that the appellant had subjected her to cruelty and money demands; on the night before her death, neighbours heard a quarrel between them.

The next morning, the deceased was found dead inside the matrimonial home.

The post-mortem doctor attributed her death to asphyxia caused by manual strangulation and opined that it was homicidal.

The appellant denied the allegations in his Section 313 CrPC examination and offered no explanation for the death.

The Sessions Court convicted him, and he appealed against that conviction and sentence

Whether the prosecution proved beyond reasonable doubt, by circumstantial evidence, that the appellant committed the homicidal death of his wife

Whether the appellant’s failure to explain the death, in light of the circumstances proved by the prosecution, could be considered under Section 106 of the Evidence Act

Section 302 IPC criminalises murder.

In a case based on circumstantial evidence, the prosecution must prove each circumstance and establish a complete chain pointing exclusively to the accused’s guilt; suspicion alone cannot substitute for proof

Section 106 of the Evidence Act does not relieve the prosecution of its burden to prove guilt, but where foundational facts are established and a relevant fact is especially within the accused’s knowledge, failure to offer a reasonable explanation may provide an additional link in the chain

The Court also relied on the medical evidence as expert evidence concerning the cause and nature of death

The Court found that the medical evidence established death by manual strangulation and that the death was homicidal.

It accepted the evidence of family members and neighbours concerning the appellant’s prior cruelty and demands for money, and the neighbours’ evidence that they heard a quarrel between the couple on the preceding night.

The deceased was found dead inside the matrimonial home, while the appellant was absent when others arrived; he gave no explanation either in his defence or under Section 313 CrPC as to how she died.

The Court treated that failure as an additional link—not as a substitute for the prosecution’s proof—and concluded that the circumstances formed a complete chain pointing to the appellant’s guilt.

The appeal was dismissed, and the conviction and sentence were affirmed