Recently, the Allahabad High Court was confronted with a disturbing chain of events surrounding the mysterious death of a young woman whose body was discovered in an open field under suspicious circumstances. What initially appeared to be a routine family visit soon unraveled into allegations of marital tension, a suspected extramarital involvement, and a night marked by unanswered questions. As the judges examined medical records, location data, witness recollections, and competing narratives, the matter evolved into a deeper inquiry into responsibility, conduct, and circumstantial links.
Brief Facts:
The case arose from a complaint lodged by the mother of the deceased alleging that her daughter was last taken away by her husband on a motorcycle and was found dead the next morning in a nearby field. The body bore a ligature mark around the neck, and the post-mortem confirmed death by strangulation. On this basis, an FIR was registered under Section 302 of the Indian Penal Code, 1860 for murder.During the investigation, the police prepared the site plan, recovered broken bangles from the spot, seized the accused’s mobile phone, and obtained call detail records showing his location near the place of occurrence around the relevant time. The charge-sheet under Section 302 IPC was submitted after recording witness statements and completing the investigation.The case was then committed to the Sessions Court, where charges under Section 302 IPC were framed, to which the accused pleaded not guilty and sought trial.
Contentions of the Appellant:
The counsel for the Appellant argued that the prosecution relied entirely on circumstantial evidence without any eyewitness. The counsel submitted that the “last seen” account was unreliable because one witness admitted she never saw the two leaving together, and another had inconsistencies regarding his presence. The alleged motive of an illicit relationship, he argued, was based only on hearsay without independent proof. The Appellant contended that the chain of circumstances was incomplete and incapable of ruling out other possibilities, and that medical findings did not connect the act to him.
Contentions of the State:
The State argued that the circumstances formed a clear and coherent chain pointing towards the appellant. It relied on multiple testimonies indicating marital discord, the fact that the deceased was last seen with the appellant shortly before the body was found, and location data placing his mobile device near the incident site. The recovery of broken bangles, continuous phone contact with another woman, and the appellant’s conduct after the incident were cited as reinforcing circumstances. The State contended that no plausible alternative explanation existed.
Observation of the Court:
The Court observed that since the case was built entirely on circumstantial evidence, the prosecution had to satisfy the strict standard governing such trials. The Bench relied on the principles laid down in Sharad Birdhi chand Sarda v. State of Maharashtra, noting that circumstantial evidence cannot rest on suspicion or partial inferences but must form a complete and unbroken chain. “The circumstances from which the conclusion of guilt is to be drawn should be fully established. It may be noted here that this Court indicated that the circumstances concerned “must or should” and not “may be” established. There is not only a grammatical but a legal distinction between “may be proved” and “must be or should be proved.”
The Court further examined the medical evidence and found that the nature of injuries ruled out any possibility of accidental or self-inflicted death. The post-mortem opinion describing ante-mortem strangulation was treated as a firm starting point, making it necessary for the remaining circumstances to be evaluated around this finding. The Bench noted that the testimony clearly established that the injuries were deliberate and required external force “the death was caused due to ante-mortem strangulation and immediate cause of death is asphyxia. This Court notes that the said post mortem report has been proved by PW-5, Dr. Arun Kumar Sachan who has stated in his testimony that the death was caused by tightening of rope on the neck, which was not possible to be done individually by the deceased herself and the death has happened in the intervening night”
The Court then considered the accused’s silence regarding circumstances within his special knowledge. Once the prosecution showed that the accused and deceased were last together shortly before the death, the Court held that an explanation was expected. Relying on Trimukh Maroti Kirkan v. State of Maharashtra, it observed that an accused's failure to account for such circumstances reinforces the prosecution’s chain “when an incriminating circumstance is put to the accused and the said accused either offers no explanation or offers an explanation which is found to be untrue, then the same becomes an additional link in the chain of circumstances to make it complete”
The Court concluded that when the medical findings, the last-seen circumstance, the accused’s non-explanation, and the corroborative evidence were viewed together, they satisfied the “five golden principles” of circumstantial evidence. The cumulative effect, and not isolated facts, guided the Court’s assessment.
The decision of the Court:
The Court held that the prosecution had successfully established a complete and unbroken chain of circumstances proving homicidal death and the accused’s involvement beyond reasonable doubt. It found the medical evidence, last-seen circumstance, call records, and the accused’s failure to explain key facts to be decisive links. The conviction under the penal provision for murder was upheld, and the sentence imposed by the Trial Court was affirmed.
Case Title: Jitendra Pal V. State of U.P
Case No.: Criminal Appeal No. – 2259 of 2017
Coram: Hon’ble Mr Justice Abdhesh Kumar Chaudhary and Hon’ble Mr Rajesh Singh Chauhan,
Counsel for the Petitioner: Adv. Akash Dikshit, Adv. Neeraj Singh, Adv.Rajesh Kumar Sharma
Counsel for the Respondent: Govt. Advocate
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