Circumstantial evidence proved the husband’s guilt for his wife’s strangulation murder and cruelty beyond reasonable doubt.

The deceased, Yashoda, was the appellant’s wife.

The prosecution case was that the appellant suspected her of having an illicit relationship with PW5, ill-treated her, and took her from her mother’s house on 2 July 2018.

The next morning, Yashoda’s body was found near a railway bridge, with a veil around her neck. Medical evidence attributed her death to ligature strangulation.

The appellant was found nearby after consuming poison and was hospitalised; after his discharge, he was arrested.

The Sessions Court convicted him under Sections 498-A and 302 of the IPC. He appealed under Section 374(2) CrPC.

1. Whether the prosecution proved beyond reasonable doubt that the appellant committed Yashoda’s murder, punishable under Section 302 IPC.

2. Whether the evidence established that the appellant subjected Yashoda to cruelty punishable under Section 498-A IPC.

The Court applied Section 302 IPC to the charge of murder and Section 498-A IPC to the charge of cruelty.

It assessed the prosecution evidence—including witness testimony, medical evidence and the circumstances surrounding the death—and considered the appellant’s failure to explain the incident when examined under Section 313 CrPC.

The judgment cites no separate precedent or elaborated legal test.

The Court accepted the testimony of PW1, PW4 and PW5 as establishing that the appellant suspected Yashoda’s fidelity and physically and mentally ill-treated her, thereby proving cruelty under Section 498-A.

For the murder charge, it relied on evidence that the appellant took Yashoda away on his motorcycle, that she was later found dead by strangulation, and that the appellant was found nearby after consuming poison.

The medical evidence supported strangulation as the cause of death, and the Court also noted that the appellant gave no explanation under Section 313 CrPC.

On its reappraisal of the evidence, the Court found both charges proved beyond reasonable doubt.

It dismissed the appeal, leaving in place the sentence of one year’s rigorous imprisonment and a fine of ₹1,000 under Section 498-A, and life imprisonment and a fine of ₹5,000 under Section 302, with the respective default sentences.