Last-seen evidence and failure to explain homicidal injuries sustain a murder conviction.

The appellant and his wife, Gowramma, worked and lived at a poultry farm. On 10 March 2018, the farm owner (PW.1) saw the appellant assault Gowramma with a wooden club during a quarrel and then take her into their shed.

The next day, the appellant told their daughter (PW.4) that he had killed her mother and gave her the shed key. PW.1 and others found Gowramma’s body inside the locked shed. The post-mortem attributed death to shock and haemorrhage from her injuries; clubs seized during the investigation were found stained with human blood of the deceased’s blood group.

The Sessions Court convicted the appellant under Section 302 IPC and sentenced him to life imprisonment and a fine. He appealed, challenging the sufficiency of the evidence and, alternatively, contending that the assault occurred during a quarrel without an intention to kill.

Whether the prosecution evidence established beyond reasonable doubt that the appellant caused Gowramma’s death and sustained his conviction under Section 302 IPC

Whether the circumstances of the assault and the alleged quarrel warranted treating the offence as something other than murder under Section 300 IPC

The Court applied Sections 300 and 302 of the Indian Penal Code: conduct falling within the definition of murder under Section 300 is punishable under Section 302.

In assessing the prosecution case, it considered the circumstantial evidence, including the appellant and deceased being together before the death, the appellant’s conduct and failure to explain how the deceased sustained her injuries, the medical evidence, and the recovery of blood-stained clubs.

The Court accepted PW.1’s evidence that the appellant assaulted Gowramma with a club and took her into the shed, and PW.4’s evidence that the appellant later admitted killing her and handed over the key.

The deceased was found inside the locked shed with multiple injuries, and the medical evidence established death from those injuries. The blood-stained club recovered at the appellant’s instance supported the prosecution case.

The Court found no evidence that a further quarrel occurred inside the shed, and the appellant offered no explanation for the fatal injuries. It therefore rejected both the alternative theory of accidental injury and the argument that the assault during a quarrel displaced liability for murder.

The appeal was dismissed.

The Court also directed the Member Secretary of the District Legal Services Authority, Doddaballapura, to ensure implementation of the trial court’s directions concerning the welfare, education, health, and compensation of the deceased’s five children, if not already implemented.