Supreme Court upholds life sentence in wife’s murder, directs surrender after bail cancellation

A bench of Justices Aravind Kumar and Sandeep Mehta heard an appeal against the Bombay High Court’s affirmation of a trial court conviction under Section 302 IPC for the homicidal death of a woman in Amravati. The Special Leave Petition challenged the High Court’s judgment which had upheld the trial court’s finding that the accused-appellant caused fatal head injuries to his wife.

The Court dismissed the appeal and affirmed the conviction and life sentence imposed by the trial court, holding that the prosecution had proved guilt beyond reasonable doubt. The judges said the case rested on cogent medical evidence and reliable ocular testimony of a child who was present in the house at the time of the incident, and noted the accused’s shirt was stained with the deceased’s blood at the time of arrest. The Court, in its reasoning, observed: “On the contrary, in terms of Section 106 of the Evidence Act, the burden rested upon the accused-appellant to offer a credible explanation as to under what circumstances the deceased Smt. Ranjana, sustained the fatal injuries, particularly when the incident took place within the four walls of the house where the accused-appellant resided with the deceased Smt. Ranjana.” The Court further described the child witness as “a witness of sterling worth” whose testimony it found “absolutely natural.”

Background

The criminal case arose from the death of Smt. Ranjana, which medical evidence established was homicidal and caused by blunt weapon injuries to the head. The accused-appellant, who lived with the deceased and their children, was convicted by the Additional Sessions Judge, Amravati, on 14 August 2007 and sentenced to life imprisonment with a fine; the Bombay High Court, Nagpur Bench, dismissed his appeal on 1 April 2011. The prosecution’s case primarily relied on the testimony of the couple’s nine-year-old daughter, who said she was sleeping beside her mother, woke on hearing a commotion, saw her father sitting nearby with the body covered by a chaddar, and was told not to remove it. She said her father then left the house and did not return. Her testimony was corroborated on material aspects by the landlord and by post-mortem evidence given by the medical jurist.

The accused offered a blank denial in his 313 CrPC statement and the defence suggested possible tutoring of the child witness and an alternative account that the father had gone out searching for a son. The Court rejected those contentions as flimsy, noting that the child maintained her account in cross-examination and that the accused’s blood-stained shirt linked him to the victim. The Supreme Court accepted the High Court’s reappreciation that the prosecution had discharged its burden and that, under Section 106 of the Evidence Act, the accused had failed to provide a credible explanation when the incident occurred within the four walls of the house.

The appeal was dismissed as devoid of merit. The Court noted that it had earlier granted interim bail to the accused by order dated 10 December 2018; with dismissal of the appeal, the bail bonds stood cancelled and the accused was directed to surrender before the trial court within four weeks and undergo the remainder of the sentence, failing which the trial court was to take steps to ensure apprehension. All pending applications stood disposed of.

Case No.: CRIMINAL APPEAL NO(S). 1021 OF 2012 (2025 INSC 953) Case Title: Manohar Keshavrao Khandate v. State of Maharashtra Appearances: For the Petitioner(s): [Not indicated in the judgment] For the Respondent(s): [Not indicated in the judgment]