Manohar Keshav Rao Khandate v. The State of Maharashtra
Background
The appellant was convicted by the Amravati Sessions Court and had that conviction upheld by the Bombay High Court (Nagpur Bench) for murdering his wife, Ranjana, at their home. The prosecution's central evidence came from the couple's nine-year-old daughter, who testified that her father, who used to beat her mother after drinking, was found sitting beside her mother's body (covered with a bedsheet) when she woke to a commotion; he told her not to remove the sheet and then left the house, never to return. When the child later removed the sheet, she found her mother bleeding from head injuries and alerted the landlord, who called the police.
Decision Breakdown
The Supreme Court dismissed the appeal and upheld the conviction and life sentence. It held that the child witness's testimony was natural, consistent, and unshaken in cross-examination, and was independently corroborated by the landlord's testimony and medical evidence confirming the death was homicidal, caused by blunt-force head injuries. The Court found the accused was the only other able-bodied adult present in the house at the time, that his instruction to the child not to look under the sheet followed by his abscondence indicated a guilty conscience, and that his bloodstained shirt (matching the deceased's blood group) further connected him to the crime. Because the incident occurred entirely within the four walls of the couple's own home, the burden under Section 106 of the Evidence Act shifted to the accused to explain the circumstances of his wife's death, which he failed to do, offering only a bare denial. The Court also cancelled the appellant's bail (which had been granted pending appeal) and directed him to surrender within four weeks to serve out the remainder of his life sentence.
Lesson Learnt
A conviction can rest on the credible, corroborated testimony of a child witness, and when a fatal incident occurs inside a person's own home with no other adults present, the law places a burden on that person to explain what happened: silence or a bare denial will not be enough to escape liability.