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Manju v. State of Delhi

Criminal Appeal · 2019 INSC 1385Decided 17 Dec 2019
Criminal Appeal No. 1268 of 2013
Justice Mohan M. Shantanagoudar · Justice R. Subhash Reddy

Background

The appellant gave birth to a baby girl at a Delhi hospital in August 2007, and the baby was later found dead, allegedly strangled. The trial court convicted the mother of murder under Section 302 IPC and sentenced her to life imprisonment, a conviction the Delhi High Court upheld. She appealed to the Supreme Court, arguing that the conviction was based on unproven assumptions, including the theory that she killed the child because it was a girl.

Decision Breakdown

The Supreme Court found that the prosecution's case rested entirely on circumstantial evidence and that the chain of circumstances required for a conviction on that basis was not established. The Court noted the baby had been placed in an incubator with an oxygen mask and had not cried or opened her eyes after birth, raising a real possibility of natural death, and that no credible motive was shown for the mother to kill her own child. It held that the trial court and High Court had wrongly based the conviction on presumption rather than proof, and that in the absence of clear evidence the benefit of the doubt had to go to the accused. The Court allowed the appeal, set aside both lower court judgments, and acquitted the appellant.

Lesson Learnt

A criminal conviction, especially one based only on circumstantial evidence, cannot rest on suspicion, assumption, or an unproven motive: the prosecution must establish a complete and unbroken chain of facts pointing only to the accused's guilt, or the accused is entitled to acquittal.

Official source (sci.gov.in)View Judgment (PDF)

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