Inquest and medical examination preceding FIR registration do not vitiate a trial if ocular testimony is reliable.

The Appellant was convicted under Section 302 of the IPC for the murder of his wife, Sangita, on the night of March 31, 2019.

The prosecution’s case, led by the mother of the deceased (PW 1), alleged that the Appellant, an alcoholic who suspected his wife’s character, assaulted her with an axe following a quarrel.

PW 1 discovered the victim in a pool of blood and saw the Appellant fleeing the scene.

The Police arrived at approximately 3:15 a.m., conducted an inquest, and sent the body for post-mortem before formally registering the FIR at 11:29 a.m. on April 1, 2019.

The Appellant was arrested on April 4, 2019, in Karnataka.

The Trial Court sentenced him to life imprisonment.

1. Whether the commencement of investigative steps (inquest and post-mortem) prior to the registration of the FIR vitiates the trial.

2. Whether the delay in lodging the FIR and the non-examination of all listed witnesses creates reasonable doubt regarding the Appellant's guilt.

3. Whether the Appellant’s plea of alibi and the inconclusive Chemical Analyzer (CA) report entitle him to an acquittal.

The court applied Section 302 of the IPC regarding the punishment for murder.

It relied on *Harijan Jivrajbhai Badhabhai v. State of Gujarat*, establishing that conducting an inquest before an FIR does not necessarily demolish the prosecution case if the evidence inspires confidence.

Regarding FIR delay, it applied *Ravinder Kumar v. State of Punjab*, holding that delay is not fatal if the cause is not attributable to concoction.

The court utilized Section 8 of the Indian Evidence Act, 1872, to treat absconding as relevant conduct.

It further affirmed that the quality, not quantity, of evidence matters per *CBI v. Mir Usman*.

The court utilized Section 11 regarding the 'strict scrutiny' required for a plea of alibi, as seen in *Kamal Prasad v. State of M.P.*.

The Court found that the investigative steps taken before the FIR (inquest and medical transit) did not prejudice the Appellant, as the actual collection of incriminating material (seizure of weapon/clothes) occurred after registration.

The 10-hour delay in the FIR was excused due to the traumatic nature of the event—a mother discovering her daughter's brutalized body while caring for two toddlers at night.

The Court upheld the reliability of PW 1 as a "natural witness" whose testimony remained unshaken during cross-examination.

The Appellant’s plea of alibi failed because he provided no evidence to prove he was at work.

Furthermore, his conduct in fleeing to Karnataka was deemed a "relevant piece of evidence" under Section 8 of the Evidence Act.

Medical evidence (PW 3) corroborated that the chop wound on the neck was caused by a heavy sharp weapon like the recovered axe.

The procedural delays and the lack of independent witnesses did not override the consistent ocular and medical evidence.

The High Court dismissed the appeal and upheld the conviction and life sentence passed by the Additional Sessions Judge, Pune.