Conviction under Section 302 IPC sustained based on circumstantial evidence and presumption under Section 106 Evidence Act.

The appellant, Roshan Lal, was convicted under Section 302 IPC for the murder of his wife, Rupa, by the 1st Additional Sessions Judge, Rishikesh

The prosecution alleged that on the night intervening October 31 and November 1, 2017, the appellant strangulated his wife with a clutch/brake wire in their rented room due to suspicions regarding her character

The appellant himself informed the police at 4:35 a.m. that he had committed the murder

Medical evidence confirmed the cause of death as asphyxia due to strangulation

The appellant contended that his wife committed suicide and that the case was based on false allegations by her family

1. Whether the death of the deceased was homicidal or suicidal in nature

2. Whether the prosecution established a complete chain of circumstantial evidence to convict the appellant under Section 302 IPC

3. Whether the burden of proof shifted to the appellant under Section 106 of the Evidence Act to explain the death of his wife within the shared matrimonial home

Section 302 of the Indian Penal Code (IPC) for murder

Section 106 of the Indian Evidence Act, 1872, which places the burden of proving facts especially within the knowledge of a person upon that person

The "Panchsheel" principles of circumstantial evidence established in Sharad Birdhichand Sarda v. State of Maharashtra

The medical-legal principle from Godabarish Mishra v. Kuntala Mishra, which states that suicide by self-strangulation is virtually impossible without a specific contrivance to maintain pressure, thus distinguishing homicidal strangulation

The court found that the prosecution successfully established a motive rooted in the appellant’s suspicion of the deceased’s character, supported by testimonies of the landlord (PW2) and neighbors (PW6, PW8) regarding frequent quarrels

The medical evidence (PW3) was pivotal: the presence of struggle marks, bleeding from the nose/ear, and a deep ligature mark encircling the neck ruled out suicide, as self-strangulation is medically rare without a mechanical aid

Since the appellant and deceased were alone in their room with their minor daughter, the court held that the appellant failed to discharge his burden under Section 106 of the Evidence Act to explain the homicidal death

The recovery of the weapon (clutch wire) at the appellant's instance and his immediate conduct of reporting the matter to the police (corroborated by GD entries) created an unbroken chain of circumstances

The court dismissed the appeal, affirming the judgment of the trial court and upholding the sentence of life imprisonment and a fine of Rs. 10,000

The court ordered the records to be transmitted back to the lower court