Mother-in-Law and Sister-in-Law Acquitted in Murder Case: Supreme Court’s Verdict

The Supreme Court of India recently delivered its verdict in the criminal case of Smt. Chintambaramma & Anr. vs. State of Karnataka, addressing crucial issues related to circumstantial evidence, wrongful conviction, and the principles of justice. The appellants, mother-in-law and sister-in-law of the deceased, were convicted under Section 302 read with Section 34 IPC for murder and sentenced to life imprisonment by the lower courts. However, after analyzing the evidence, the Supreme Court ruled in favor of acquittal, citing the prosecution’s failure to establish a complete chain of circumstances linking the accused to the crime.

Background of the Case

The case revolves around the death of Sahitya, who was married to L. Manjunatha on March 10, 2006. On August 25, 2009, Sahitya was found dead in her marital home. Her mother, Anjanamma, filed an FIR, alleging that Sahitya had been murdered by her husband’s family members, including the appellants and other relatives.

The prosecution’s case was primarily based on circumstantial evidence, with the investigating officer alleging that Sahitya was murdered by her mother-in-law, Chintambaramma, and sister-in-law, Saraswathi, in conspiracy with others. Initially, the case also involved allegations of dowry harassment. However, during the trial, several key witnesses, including Sahitya’s relatives, turned hostile and denied that she was harassed for dowry.

Charges Framed

The trial court framed the following charges against the accused:

• Receiving Rs. 4 lakhs cash and 100 grams of gold as dowry at the time of marriage under Section 3 of the Dowry Prohibition Act.
• Subjecting the deceased to cruelty for dowry under Section 498-A IPC.
• Conspiring to murder Sahitya under Section 120-B IPC.
• Committing her murder by strangulation under Section 302 read with Section 34 IPC.

Trial Court and High Court Verdicts

The trial court found the allegations of dowry harassment unsubstantiated due to lack of evidence. It also acquitted some of the co-accused but convicted the appellants, relying on circumstantial evidence, and sentenced them to life imprisonment.

On appeal, the High Court upheld their conviction but acquitted the deceased’s husband, L. Manjunatha. The High Court observed that the behavior of the appellants raised suspicion, as they were present at the crime scene and later attempted to mislead others about Sahitya’s death.

Supreme Court’s Analysis

The Supreme Court examined the following key aspects while deciding the appeal:

1. Lack of Direct Evidence

The Court noted that the prosecution’s case was entirely based on circumstantial evidence, with no eyewitnesses to the crime. Several prosecution witnesses, including Sahitya’s own family members, did not support the allegations of dowry harassment or prior ill-treatment.

2. Contradictions in the Prosecution’s Case

The Court pointed out that the prosecution initially claimed that two other accused (A4 and A5) had committed the murder in conspiracy with the appellants. However, these two individuals were never apprehended. Later, the prosecution shifted its stance, alleging that only the appellants were involved. The Court found this inconsistency problematic.

3. Incomplete Chain of Circumstances

The Supreme Court referred to previous judgments emphasizing that in cases based on circumstantial evidence, the prosecution must establish a complete chain of events leading to the accused’s guilt without any reasonable doubt. The Court observed:

“The chain of circumstances has not been completed so as to lead only one conclusion that the appellants and the appellants alone were responsible for committing the crime.”

4. Role of the Investigating Officer

The Court found that the Investigating Officer had manipulated the case by introducing false conspiracy theories to protect the real culprits. The officer botched up the investigation, leading to an erroneous conviction.

5. Violation of Legal Principles

The Supreme Court referred to the legal principle that failure to frame a proper charge under Section 302 IPC is an illegality that can vitiate the conviction. It cited Willie Slaney v. State of Madhya Pradesh and Main Pal v. State of Haryana, stating that the prosecution cannot convict someone under a charge they were not specifically tried for.

Final Judgment

Based on these findings, the Supreme Court ruled:

“Since the prosecution proceeded on the basis that the appellants conspired with others but failed to prove the conspiracy, their conviction under Section 302 IPC cannot be sustained. Such conviction has caused not only prejudice but also failure of justice.”

The Court thus acquitted the appellants and ordered their immediate release.

Conclusion

This judgment highlights the importance of a thorough and unbiased investigation in criminal cases. It reiterates the principle that conviction must be based on strong evidence and a complete chain of circumstances, not mere suspicion. The ruling serves as a reminder that procedural lapses and investigative shortcomings can lead to wrongful convictions, necessitating careful judicial scrutiny to uphold justice.

Petitioner Name: Smt. Chintambaramma & Anr..
Respondent Name: State of Karnataka.
Judgment By: Justice L. Nageswara Rao, Justice Hemant Gupta.
Place Of Incident: Karnataka.
Judgment Date: 22-08-2019.

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