Allahabad HC Acquits Husband Of Wife’s Murder, Citing Accident-Consistent Injuries And Lack Of Reliable Evidence Of An Affair

The appellant was convicted under Sections 302 and 201 IPC for allegedly murdering his wife, Mamta Rani, and staging her death as a road accident.

The appellant reported that a vehicle had struck her while they were travelling by motorcycle; he called emergency services and took her to hospital, where she was declared dead.

The post-mortem recorded external injuries consistent with a motor-vehicle accident, no abnormality in the internal organs, and death by asphyxia.

The appellant appealed his conviction, arguing that the prosecution had not proved murder beyond reasonable doubt.

Sections 302 and 201 IPC concern, respectively, murder and causing disappearance of evidence or giving false information to screen an offender.

The prosecution must prove the accused’s guilt beyond reasonable doubt and bears the burden of establishing the facts in issue and relevant supporting facts throughout the trial.

Section 106 of the Evidence Act may require an accused to prove a fact especially within their knowledge, but it does not relieve the prosecution of first establishing the case against the accused; similarly, a reverse-burden provision applies only after the prosecution crosses the required threshold.

The principal witnesses were not eyewitnesses, and their accounts did not independently establish that the appellant killed the deceased or placed her body on the road.

The alleged prior complaints and marriage agreement were produced only as photocopies; the latter was also undermined by evidence that its stamp paper was issued after the stated date of execution.

The medical evidence did not exclude an accident: the doctor accepted that the injuries could have resulted from one, and no internal-organ abnormality was found.

The State’s arguments that the appellant failed to explain the absence of motorcycle damage or to produce ambulance and hospital witnesses improperly sought to shift the burden of proof to the defence.

The circumstantial evidence therefore did not establish the prosecution’s case beyond reasonable doubt.

It allowed the appeal against the convictions under Sections 302 and 201 IPC and ordered that the appellant be released if still in custody; if on bail following suspension of sentence, his bail bonds stood discharged.