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Issues Involved:
1. Circumstantial Evidence and Chain of Events 2. Motive for the Crime 3. Credibility of Witnesses 4. Statement of the Accused under Section 313 Cr.P.C. 5. Medical Evidence and Cause of Death Issue-Wise Detailed Analysis: 1. Circumstantial Evidence and Chain of Events: The prosecution's case was based on circumstantial evidence as there were no eyewitnesses to the occurrence. The Supreme Court reiterated the settled principle that an accused can be convicted on circumstantial evidence if the prosecution proves a complete chain of events and circumstances beyond reasonable doubt, pointing towards the involvement and guilt of the accused. The Court cited the case of Sharad v. State of Maharashtra, which laid down five conditions for a case based on circumstantial evidence to be fully established. These include the necessity for circumstances to be fully established, consistent only with the hypothesis of guilt, of a conclusive nature, excluding every other hypothesis, and forming a complete chain of evidence. 2. Motive for the Crime: The appellant contended that there was no motive for the crime, suggesting it was a case of suicide. However, the Court noted that the deceased had left her earlier husband and was living with the appellant, who faced social embarrassment due to their living arrangement. The villagers had protested against their cohabitation, providing a plausible motive for the appellant to commit the crime. The Court emphasized that while motive is not absolutely essential for securing a conviction, it can be a significant factor when established. The Court referenced Bhimapa Chandappa Hosamani v. State of Karnataka, highlighting that failure to prove motive is not fatal if the evidence is otherwise convincing. 3. Credibility of Witnesses: The prosecution examined four witnesses, including the Investigating Officer and the doctor who conducted the postmortem. The Court found the testimonies of the prosecution witnesses credible and consistent. The most crucial witness, PW3 Dr. Bidhu Bhushan Singh, confirmed that the deceased had been throttled before being burnt. The appellant's failure to examine Bhola Babu, whom he claimed had helped him, further weakened his defense. The Court noted that the testimony of PW1, who saw the deceased in a burnt condition, was truthful and consistent with the prosecution's case. 4. Statement of the Accused under Section 313 Cr.P.C.: The appellant's statement under Section 313 Cr.P.C. was scrutinized, where he admitted that the deceased was his wife and had died of burn injuries but claimed it was a suicide. The Court emphasized that the purpose of Section 313 is to provide the accused an opportunity to explain incriminating evidence. The appellant's denial of the murder and his claim of suicide were disbelieved by the Court, as his explanation was inconsistent with the medical evidence and other circumstances. The Court highlighted that the statement under Section 313 can be used to test the veracity of the accused's claims but cannot be the sole basis for conviction. 5. Medical Evidence and Cause of Death: The medical evidence played a crucial role in establishing the cause of death. PW3 Dr. Bidhu Bhushan Singh's postmortem report indicated that the deceased had died due to asphyxia caused by throttling, followed by burn injuries. The Court noted that the medical evidence was consistent with the prosecution's case and excluded the possibility of suicide. The presence of injuries such as a protruding tongue, swollen larynx, and trachea, and a fractured skull further corroborated the prosecution's theory of murder followed by an attempt to burn the body to destroy evidence. Conclusion: The Supreme Court found no infirmity in the judgments of the Trial Court and the High Court, which had both convicted the appellant based on the established chain of circumstantial evidence, credible witness testimonies, and consistent medical evidence. The appeal was dismissed, upholding the conviction and sentence of the appellant for the offences under Sections 302 and 201 of the IPC.
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