Husband Must Explain Wife’s Unnatural Death in the Matrimonial Home, Rules Supreme Court

Husband Must Explain Wife’s Unnatural Death in the Matrimonial Home, Rules Supreme Court in Ramkishan Digambar Jadhav v. State of Maharashtra

Case: Ramkishan Digambar Jadhav v. The State of Maharashtra
Citation: 2026 INSC 1187
Date of Judgment: 02 November 2026
Court: Supreme Court of India
Coram: Justice Sandeep Mehta and Justice Devendra Kumar Upadhyaya
Proceedings: Criminal Appeal No. 1849 of 2013 with Criminal Appeal No. 962 of 2014

Court Observation

“The failure of the appellant-Ramkishan to furnish a plausible explanation and in discharging the burden cast upon him by virtue of Section 106 of the Evidence Act coupled with the introduction of a false defence, provides an additional incriminating link that completes the chain of circumstantial evidence, and thereby establishing his guilt for the offence of murder punishable under Section 302 of the IPC.”

Summary

The Supreme Court has dismissed the appeals of a husband and his relatives and upheld the husband’s conviction and life sentence for the murder of his wife, who died an unnatural death inside their matrimonial home within nine months of their marriage. The convictions for cruelty and dowry death were also sustained.

The Court held that where a woman dies unnaturally inside a house where she is in the exclusive custody and company of the accused, the burden under Section 106 of the Indian Evidence Act, 1872, shifts to the accused to provide a plausible explanation. Coupled with the statutory presumption under Section 113B of the Evidence Act where cruelty or harassment linked to a dowry demand is shown soon before death within seven years of marriage, the husband’s failure to explain the death and his false defence completed the chain of circumstantial evidence against him.

Key Holdings

  • When an unnatural death takes place inside a house where the victim is in the exclusive custody and company of the accused, the burden under Section 106 of the Evidence Act shifts to the accused to furnish a plausible explanation.
  • Where an unnatural death occurs within seven years of marriage and there is evidence of cruelty or harassment linked to dowry demands soon before death, the statutory presumption under Section 113B of the Evidence Act is triggered, and the burden shifts to the accused to rebut it with cogent evidence.
  • The failure to discharge the burden under Section 106, coupled with a false defence, provides an additional incriminating link completing the chain of circumstantial evidence.
  • Appellate interference is not warranted where the chain of circumstantial evidence stands complete and the conviction is well founded.

Background

The husband, his father and his brother were tried in Sessions Case No. 23 of 1996 before the Additional Sessions Judge, Biloli, District Nanded. The trial court convicted them for cruelty and dowry death under Sections 498A and 304B read with Section 34 of the Indian Penal Code, but acquitted the husband of murder. The Bombay High Court at Aurangabad, by its common judgment dated 03 July 2013, reversed the acquittal, convicted the husband for murder under Section 302 of the Indian Penal Code and sentenced him to life imprisonment, while affirming the convictions for cruelty and dowry death. The husband and his co-convicts appealed to the Supreme Court. The appeal of the father stood abated as he died during the pendency of the proceedings, and the remaining appeals have now been dismissed.

Judgment Link: Read the full judgment (PDF)

Disclaimer: This is a summary prepared for informational purposes only and does not constitute legal advice. Readers should refer to the official judgment for the authoritative text.

Tags: , ,