No Eyewitness To Wife’s Murder At Home, But Jharkhand HC Upholds Husband’s Life Sentence for Her Killing

The appellant was convicted under Section 302 IPC for the murder of his wife and sentenced to life imprisonment and a fine.

The prosecution had no eyewitness to the assault.

The deceased’s body was found at the appellant’s house, where the appellant was present when the informant arrived.

The post-mortem disclosed multiple injuries, including fractures to the skull and ribs; the doctor attributed death to haemorrhage and shock from head and chest injuries caused by a hard and blunt object.

In his examination under Section 313 CrPC, the appellant said he had been in the forest and did not know how the death occurred, but called no defence witnesses.

The trial court convicted him, and he appealed.

Section 302 IPC applies where the prosecution proves that the accused committed murder.

The prosecution retains the primary burden of proving the case beyond reasonable doubt; once foundational facts are established, Section 106 of the Indian Evidence Act places on a person with special knowledge a duty to explain facts particularly within that person’s knowledge, including how an occurrence inside the home took place.

The court relied on State of Madhya Pradesh v. Balveer Singh, (2025) 8 SCC 545, for the principle that a person residing in a house must offer a cogent explanation when an occurrence takes place within it and the prosecution has established the foundational facts.

A statement under Section 313 CrPC is not substantive evidence.

The court found that the medical evidence established a homicidal death: the deceased had multiple injuries, and the doctor stated that all the injuries could not have resulted from a single fall.

The body was found in the appellant’s house, and the investigating officer described signs of dragging and struggle in its courtyard.

The court treated the appellant’s presence at the house and the place of occurrence as foundational facts.

His assertion that he had been in the forest was unsupported and, as a Section 313 statement, did not itself prove that defence.

Applying Section 106 and the cited precedent, the court held that the appellant’s failure to explain the circumstances, considered alongside the prosecution evidence, supported the inference of guilt; the medical evidence also contradicted the suggested accidental-fall explanation.

It found no basis to interfere with the trial court’s judgment, dismissed the appeal, dismissed any pending interlocutory applications, and directed that the trial court record be returned to the concerned court.