Nagendra Sah v. State of Bihar: Supreme Court Acquits Man Convicted for Wife’s Murder
The case of Nagendra Sah v. The State of Bihar involved the conviction of a man accused of murdering his wife. The prosecution alleged that he had strangled her and attempted to cover up the crime by burning her body. However, the Supreme Court found inconsistencies in the prosecution’s case and ultimately acquitted the appellant.
Background of the Case
Nagendra Sah was accused of murdering his wife on November 18, 2011. The case initially began as an unnatural death investigation based on a report filed by a villager, Mahesh Sah. The police treated it as an accidental fire incident. However, after an autopsy was conducted on the same day, the medical examiner stated that the cause of death was “asphyxia due to pressure around the neck by hand and blunt substance.” The police subsequently registered an FIR on August 25, 2012, nearly nine months later, under Section 302 (murder) of the IPC.
The Sessions Court convicted the appellant and sentenced him to life imprisonment under Section 302 and a three-year sentence under Section 201 (causing disappearance of evidence). The conviction was upheld by the Patna High Court. The appellant challenged the decision in the Supreme Court.
Key Issues Raised
- Whether the prosecution had provided sufficient evidence to prove that the appellant had murdered his wife.
- Whether the post-mortem report alone was enough to convict the appellant in the absence of any eyewitnesses.
- Whether the delay in registering the FIR impacted the credibility of the case.
Arguments by the Appellant
The defense argued that:
- None of the prosecution witnesses, including neighbors and family members, supported the murder charge.
- The post-mortem report was the only piece of evidence against the accused, which could not be sufficient to convict him beyond a reasonable doubt.
- The deceased’s mother and brother testified that she died accidentally while boiling milk for her child.
- The FIR was lodged nine months after the incident, even though the post-mortem report was available on the same day.
- The defense relied on the precedent of Balaji Gunthu Dhule v. State of Maharashtra (2012) 11 SCC 685, where the Supreme Court ruled that a post-mortem report alone cannot form the basis for conviction.
Arguments by the Prosecution
The prosecution contended that:
- The autopsy report confirmed strangulation as the cause of death, proving that it was a case of homicide and not an accident.
- The appellant was last seen with the deceased, and as per Section 106 of the Indian Evidence Act, the burden was on him to explain how his wife died.
- The appellant tried to mislead the investigation by claiming his wife died due to accidental burns.
Supreme Court’s Analysis
The Supreme Court, comprising Justices Ajay Rastogi and Abhay S. Oka, examined the case and found the following inconsistencies:
- Lack of Direct Evidence: No witnesses testified to seeing the appellant commit the crime.
- Contradictory Statements: All the neighbors and family members, including the deceased’s mother, testified that she died accidentally.
- Delay in FIR Registration: Despite the autopsy report being available on the day of the incident, the FIR was registered nine months later, raising doubts about the prosecution’s credibility.
- Failure to Establish Motive: There was no evidence of any prior dispute between the appellant and the deceased.
Key Observations by the Supreme Court
The Court referred to its earlier rulings on circumstantial evidence:
“Only on the basis of a post-mortem report, the appellant could not have been convicted of the offence punishable under Section 302 of IPC and consequently for the offence punishable under Section 201 of IPC.”
“When a case is based on circumstantial evidence, the chain of circumstances must be so complete that it leads to only one conclusion – the guilt of the accused. If an alternative hypothesis exists, the benefit of the doubt must go to the accused.”
Final Judgment
The Supreme Court ruled that the prosecution had failed to establish the guilt of the accused beyond a reasonable doubt. The conviction by the Sessions Court and the High Court was set aside, and the appellant was acquitted. The Court directed that he be released immediately unless required in any other case.
Legal Implications of the Judgment
This judgment sets a crucial precedent:
- Reinforcement of Burden of Proof: The burden to prove guilt beyond a reasonable doubt always remains with the prosecution.
- Importance of Corroborative Evidence: A post-mortem report alone is insufficient for conviction.
- Protection of Accused’s Rights: Courts must ensure that circumstantial evidence is strong enough to exclude any hypothesis of innocence.
Conclusion
The Supreme Court’s ruling in Nagendra Sah v. State of Bihar is a landmark decision emphasizing the importance of strong circumstantial evidence in criminal cases. By overturning the conviction, the Court reinforced the principle that suspicion, no matter how strong, cannot replace legal proof. The ruling serves as a reminder that due process and fair trials are fundamental to justice.
Petitioner Name: Nagendra Sah.Respondent Name: The State of Bihar.Judgment By: Justice Ajay Rastogi, Justice Abhay S. Oka.Place Of Incident: Bihar.Judgment Date: 14-09-2021.
Don’t miss out on the full details! Download the complete judgment in PDF format below and gain valuable insights instantly!
Download Judgment: nagendra-sah-vs-the-state-of-bihar-supreme-court-of-india-judgment-dated-14-09-2021.pdf
Directly Download Judgment: Directly download this Judgment
See all petitions in Bail and Anticipatory Bail
See all petitions in Judgment by Ajay Rastogi
See all petitions in Judgment by Abhay S. Oka
See all petitions in allowed
See all petitions in supreme court of India judgments September 2021
See all petitions in 2021 judgments
See all posts in Criminal Cases Category
See all allowed petitions in Criminal Cases Category
See all Dismissed petitions in Criminal Cases Category
See all partially allowed petitions in Criminal Cases Category
