Wife Found Dead At Matrimonial Home: Karnataka HC Acquits Husband Of Murder, Upholds Cruelty Conviction

Rukmini, who had married the appellant in 2012, was found dead in the couple’s home on 14 September 2015.

The prosecution alleged that the appellant had subjected her to cruelty and strangled her.

The trial court convicted him under Sections 498A and 302 of the Indian Penal Code (IPC), while acquitting him of the charges under Section 304B IPC and Section 4 of the Dowry Prohibition Act; the co-accused was acquitted of all charges.

On appeal, the appellant disputed the murder conviction and maintained that Rukmini had died by suicide.

Section 302 IPC criminalises murder, and a conviction requires proof beyond reasonable doubt that the accused committed the homicidal act.

Section 498A IPC addresses a husband’s subjecting his wife to cruelty.

The Court also considered the charges originally framed under Section 304B IPC and Section 4 of the Dowry Prohibition Act, though the trial court had acquitted the appellant of those offences.

No precedent is cited in the judgment.

The Court found the evidence of PWs 6 and 14 unreliable as to their presence at the house at the time alleged: their accounts of when they travelled there conflicted, and neither witnessed the killing.

The medical evidence established death by asphyxia due to neck compression but did not conclusively establish whether the ligature injury resulted from strangulation or hanging; the neighbour, PW13, supported the account that Rukmini was found hanging.

Taken together, the evidence did not justify the Section 302 conviction.

By contrast, testimony from family members, considered with Rukmini’s earlier complaint describing physical and mental abuse, supported the finding of cruelty under Section 498A.

As he had completed the sentence for the Section 498A offence, the Court directed his release unless required in another case.

It also directed the District Legal Services Committee, Shivamogga, to determine compensation for the deceased’s mother under the Karnataka Victim Compensation Scheme within three months.