Court Restores Father‑in‑Law's Murder Conviction, Finds Strangulation Followed by Fabricated Electrocution Story

A bench of Justices Sanjay Kumar and Alok Aradhe heard the State of Madhya Pradesh’s appeal challenging the Gwalior Bench of the Madhya Pradesh High Court which had set aside the trial court’s conviction and sentence of the father‑in‑law in the death of his daughter‑in‑law; the scope of the appeal was confined to respondent No.1, Janved Singh, after an earlier order disposed of the challenge in respect of the husband.

The Court allowed the appeal in part, set aside the High Court’s acquittal of Janved Singh and restored the Sessions Court’s conviction and sentence insofar as they pertained to him. The Supreme Court concluded that the post‑mortem and other evidence established homicidal death by strangulation and that Janved Singh had attempted to mislead the investigation by fabricating a false story of electrocution. The Court reiterated settled principles that a murder conviction could rest on circumstantial evidence where the “chain of circumstances is complete and consistent only with hypothesis of the guilt of the accused,” and that a false explanation by an accused could constitute an additional link in that chain. The Court, in its reasoning, observed: "From the evidence adduced by the prosecution, it has established the complete chain of circumstances namely, (i) the unnatural death of the deceased which was not accidental but homicidal as established from the medical evidence, (ii) the death occurred inside the house occupied by accused No.1 which was under his control, (iii) the FIR lodged by accused No.1 himself establishes his presence in the house at the relevant time, (iv) the version of the accused No.1 that he had gone to the field is wholly unsubstantiated by any witness or independent corroboration, (v) the deliberate lodging of a false report of electrocution and an attempt to mislead the investigation, (vi) the strained relations between son of accused No.1 and his daughter-in-law and persistent demands for dowry. Each link fits seamlessly with the next, forming a continuous chain which points unerringly to the guilt of accused No.1 and excludes all reasonable hypothesis of innocence. Once the aforesaid circumstances pointing out the guilt of the accused No.1 was proved, the burden was on the accused No.1 to explain the circumstances under which the deceased died in the house occupied by him. The accused No.1 has miserably failed to discharge the aforesaid burden." The Court further stated that the post‑mortem left "no manner of doubt that death of the deceased was homicidal."

Background The dispute arose after the death of Smt. Pushpa on 31 December 1997. The father‑in‑law, Janved Singh, initially reported that she had died from electrocution while ironing. Police registered a report under Section 174 CrPC and later converted it into a regular criminal case; the post‑mortem by Dr. Devendra Khare revealed ligature marks consistent with strangulation and indicated burns were post‑mortem. The Sessions Court, after examining 20 witnesses and documentary material, convicted Janved Singh under Sections 302, 498‑A and 201 IPC and sentenced him accordingly, concluding the electrocution story was fabricated. On appeal the High Court acquitted all accused, holding that delay in recording key testimonies, inconsistencies in documentary proof of marriage and lack of proof that death occurred within seven years of marriage undermined the prosecution’s case. The State appealed; prior to final hearing this Court dismissed the appeal in respect of the husband, leaving only Janved Singh’s acquittal in issue.

On behalf of the State it was contended that testimony of the deceased’s parents and uncle, the post‑mortem findings and evidence of dowry‑related harassment together established guilt beyond reasonable doubt, and that the father‑in‑law’s false report and uncorroborated explanation were decisive. The defence argued absence of direct or reliable circumstantial evidence linking Janved Singh to the act, delayed recording of witness statements, failure to establish the date of marriage for Section 304‑B IPC and no proof of his presence at the scene.

The Supreme Court reappraised evidence in light of settled law on circumstantial cases, Section 106 Evidence Act principles and precedents on false explanations, held that the High Court failed to consider material evidence relied upon by the trial court, and concluded that the chain of circumstances excluded reasonable hypotheses of innocence. The Court set aside the High Court’s judgment and restored the Sessions Court’s conviction and sentence in respect of Janved Singh and ordered that he be taken into custody forthwith to serve the remainder of the sentence. The appeal was thus partly allowed.

Case Details: Case No.: 2025 INSC 1229; Criminal Appeal No. 460 of 2014 Case Title: State of Madhya Pradesh v. Janved Singh Appearances: For the Petitioner(s): Counsel for State of Madhya Pradesh (not indicated in the judgment extract) For the Respondent(s): Counsel for Janved Singh (not indicated in the judgment extract)