Mother Acquitted in Infanticide Case: Supreme Court Raises Doubts Over Motive and Evidence

The case of Manju vs. State of Delhi involves the tragic death of a newborn baby and the subsequent conviction of the mother for the crime of murder under Section 302 of the Indian Penal Code. The appellant, Manju, was sentenced to life imprisonment by the Delhi High Court, a conviction which was based primarily on circumstantial evidence. The Supreme Court, however, ruled in favor of the appellant, pointing out several inconsistencies in the evidence and the lack of clear motive.

Background of the Case

The case began on August 24, 2007, when the appellant, Manju, gave birth to a baby girl at the Lady Hardinge Medical College Hospital in New Delhi. The baby was placed in an incubator with an oxygen mask, but shortly after being handed over to the mother around 4:30 p.m., the child was found dead by hospital staff. The cause of death, according to the post-mortem report, was asphyxia due to ante-mortem strangulation.

On August 31, 2007, a case under Section 302 of the Indian Penal Code was filed against the mother for allegedly strangling her newborn daughter. The appellant denied the charge, claiming that she had no intention to harm her child and had been under the influence of medication after childbirth. Despite her defense, the trial court convicted her, and the conviction was upheld by the Delhi High Court on March 12, 2010. She was sentenced to life imprisonment.

Key Legal Issues

The Supreme Court had to examine several critical issues in the case:

• Whether the evidence presented by the prosecution, mainly circumstantial, was sufficient to prove the appellant’s guilt beyond reasonable doubt.
• Whether the appellant’s motive to kill her child could be inferred from the circumstances, especially given that the child’s death occurred shortly after birth.
• Whether the trial court and the High Court had erred in convicting the appellant based on presumptions without solid evidence linking her to the crime.

Arguments by the Appellant (Manju)

The appellant, represented by Ms. Mahalakshmi Pavani, raised the following arguments:

• There were no eyewitnesses to the crime, and the death was not witnessed by any hospital staff directly.
• The appellant was in a weakened state due to the effects of medication and was drowsy, which prevented her from being fully alert when she saw the baby.
• The circumstantial evidence presented was insufficient to prove that the appellant had any intention to kill her newborn.
• There was no clear motive for the appellant to kill her child, especially considering that the family had no prejudice against having a female child.
• The timing of the post-mortem, which occurred two days after the baby’s death, and the delay in registering the case raised doubts about the investigation’s integrity.

Arguments by the Respondents (State of Delhi)

The prosecution, represented by Mr. Anmol Chandan, presented the following arguments:

• The circumstantial evidence established that the appellant was the only person with access to the child after the birth, and the baby was found dead under suspicious circumstances.
• The appellant’s actions were inconsistent with a mother’s natural instinct, as she failed to act when the child was found dead.
• The motive for the killing was inferred from the fact that the appellant had expressed disappointment over the birth of a baby girl, which could have driven her to harm the child.
• The medical evidence, including the post-mortem report, clearly indicated that the cause of death was strangulation, which was consistent with intentional harm.

Supreme Court’s Observations and Ruling

The Supreme Court, comprising R. Subhash Reddy and Mohan M. Shantanagoudar, delivered the following key observations:

1. Circumstantial Evidence and Motive

The Court examined the circumstantial evidence presented and noted that:

“Circumstantial evidence, by its nature, requires that all links in the chain of events leading to the crime be established beyond reasonable doubt. In this case, the chain is incomplete.”

The Court emphasized that the prosecution failed to conclusively establish the appellant’s motive for killing the child. The evidence, such as the appellant’s statement that she wanted a female child, was not sufficient to conclude that she killed the child intentionally.

2. Lack of Clear Evidence

The Supreme Court also noted that the trial court and High Court had based their conviction on presumptions and not on clear, concrete evidence:

“The chain of events is not established conclusively. There is no direct evidence to prove that the appellant committed the crime, and the prosecution has failed to establish guilt beyond reasonable doubt.”

The Court pointed out that no one directly witnessed the strangulation, and there was a possibility that the baby died due to natural causes, given the medical conditions present at birth.

3. Motive and Family Background

The Court considered the family background of the appellant and her spouse, which suggested that the family was not averse to having a female child:

“The evidence of PW-7 (the appellant’s husband) clearly shows that the family was not prejudiced against having a female child, which further undermines the inference that the appellant killed her child due to gender bias.”

4. Delay in Investigation

The Court observed that the delay in conducting the post-mortem and registering the case created doubts about the investigation process:

“The unexplained delay in sending the body for post-mortem and the delay in registering the crime create an atmosphere of doubt, which is detrimental to the prosecution’s case.”

5. Benefit of Doubt

The Court concluded that, based on the totality of the evidence, the appellant was entitled to the benefit of doubt:

“In view of the lack of clear evidence, and considering the appellant’s weakened state due to medication, we are of the opinion that the appellant is entitled to benefit of doubt.”

Final Judgment

The Supreme Court overturned the conviction and acquitted the appellant:

“The appellant is acquitted of the charge of murder under Section 302 IPC. The judgment of the trial court and the impugned judgment of the High Court are set aside.”

Implications of the Judgment

This ruling has significant implications for criminal law and how circumstantial evidence is treated:

• Circumstantial Evidence: Circumstantial evidence must establish a clear and complete chain of events to prove guilt beyond reasonable doubt.
• Benefit of Doubt: In criminal cases, when there is uncertainty in the evidence, the accused is entitled to the benefit of doubt.
• Motive and Evidence: A clear motive must be established to support a charge of murder, and general assumptions or stereotypes cannot be the basis for conviction.
• Investigation Procedures: Delays in post-mortem and the registration of cases can severely undermine the prosecution’s case.

Conclusion

The Supreme Court’s judgment in Manju vs. State of Delhi highlights the importance of thorough and reliable evidence in criminal cases. By acquitting the appellant, the Court reinforced the principle that justice must be based on facts, not assumptions or presumptions.

Petitioner Name: Manju.
Respondent Name: State of Delhi.
Judgment By: Justice R. Subhash Reddy, Justice Mohan M. Shantanagoudar.
Place Of Incident: Delhi.
Judgment Date: 17-12-2019.

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