Murder Conviction Upheld: Understanding the Vijay Nathalal Gohil Case

The case of Vijay Nathalal Gohil versus State of Maharashtra revolves around a conviction under Section 302 of the Indian Penal Code (IPC). The Supreme Court upheld the life imprisonment sentence awarded by the Additional Sessions Judge and affirmed by the High Court of Bombay. The appellant was acquitted of charges under Sections 498A and 304B IPC, which pertain to cruelty and dowry-related offenses.

The appellant, Vijay Nathalal Gohil, was married to the deceased, and they had two children. The prosecution established that there was a history of ill-treatment and frequent altercations between the couple. The deceased was at one point sent to her parental home but later returned to live with the appellant in a room adjacent to his embroidery factory.

Incident Leading to Conviction

On May 21, 1990, the appellant approached the police station and reported his wife’s death, claiming she had consumed poison. He handed over a bottle of poison to the police. The postmortem examination, however, revealed inconsistencies with this claim. Dr. Ashok Gangaram Shinde, the prosecution’s medical witness, found about 13 injuries around the mouth and neck, along with internal hemorrhages. He further observed 19 linear abrasions and 5 contusions, concluding that the cause of death was a violent asphyxial death due to suffocation by smothering. The presence of these injuries ruled out the possibility of suicide.

Key Evidence Considered

• The postmortem findings indicated that the injuries were ante-mortem, meaning they occurred before death.
• PW6 (Dr. Shinde) testified that the injuries found during the postmortem exceeded those recorded in the panchnama.
• The High Court noted that the appellant’s attempt to portray the death as suicide was contradicted by medical evidence.

Statements and Arguments

The prosecution presented nine witnesses, including the deceased’s brother, who observed nail marks on the cheeks and throat of the deceased. These injuries suggested resistance, further disproving the suicide claim.

During his statement under Section 313 Cr.P.C., the appellant admitted that he was present at the location at the time of death. He acknowledged:

• He lived with the deceased in the room near his factory.
• He reported her death and handed over the bottle of poison to the police.
• He was aware of the injuries observed on the deceased.

The High Court emphasized that circumstantial evidence, when taken together, formed an unbroken chain leading to the only possible conclusion: the appellant was guilty of murder.

Court’s Final Judgment

The Supreme Court ruled:

“Though the evidence may be circumstantial, the circumstances established rule out any reasonable likelihood of innocence of the appellant.”

The Court also observed:

“The attempt of the appellant to pass off the murder as a suicide by poisoning, despite unexplained fresh injuries, establishes his guilt beyond reasonable doubt.”

The trial court and High Court had concurred in their findings, and the Supreme Court found no reason to interfere with their judgment. The appeal was dismissed, affirming the life imprisonment sentence.

Petitioner Name: Vijay Nathalal Gohil.
Respondent Name: State of Maharashtra.
Judgment By: Justice Indira Banerjee, Justice Sanjiv Khanna.
Place Of Incident: Maharashtra.
Judgment Date: 03-09-2019.

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