A suspected poisoning death cannot sustain a murder conviction without proof the accused administered poison.

Reena Devi, the appellant’s wife, was found dead at their matrimonial home on 21 October 2013.

Her father’s report alleged that the appellant and his mother had assaulted and poisoned her.

The appellant was charged under Sections 302 and 328 IPC and was convicted under Section 302 IPC by the Sessions Court, which sentenced him to life imprisonment and a fine.

At trial, no witness testified to seeing the appellant administer poison or otherwise cause the death; several prosecution witnesses were hostile or had no knowledge of the incident.

The post-mortem doctor described suspected poisoning but was unable to confirm that poison had been administered or determine the cause of death with certainty.

The appellant appealed against his conviction and sentence.

1. Whether the evidence established beyond reasonable doubt that the deceased’s death was caused by poisoning administered by the appellant, sustaining his conviction under Section 302 IPC.

2. Whether the circumstantial evidence formed a complete chain sufficient to prove the appellant’s guilt.

The Court considered Section 302 IPC, under which the prosecution had to establish the appellant’s criminal responsibility for murder, and the prosecution’s allegations under Sections 328 and 34 IPC.

It applied the principle that, in a case based on circumstantial evidence, each circumstance must be proved beyond reasonable doubt and the circumstances must form a complete chain establishing guilt; conjecture or suspicion is insufficient.

The Court found that no witness placed the appellant at the scene or saw him administer poison. The room was locked from the outside and had to be opened by breaking the lock; the evidence did not establish who had locked it or that the appellant was present.

The medical evidence did not conclusively establish poisoning or show forceful administration, and the doctor was uncertain about both the cause of death and whether poison had been administered.

The Court also noted inconsistencies in the informant’s account of who had telephoned him about the incident.

It held that additional evidence sought by the State would not cure the failure to connect the appellant to the death, and that the circumstances did not complete the chain required to prove guilt.

It set aside the conviction and sentence, acquitted the appellant, and directed his release from custody; the appeal was allowed and the pending interlocutory applications were disposed of.