Nagendra Sah v. The State of Bihar
Background
The appellant's wife died of burn injuries in 2011, and years later, after an FIR was finally registered, he was convicted of her murder and sentenced to life imprisonment, based almost entirely on a post-mortem report that found the actual cause of death was strangulation, not fire. The trial court and the Patna High Court both upheld the conviction, relying on circumstantial evidence including the fact that the couple lived together.
Decision Breakdown
The Supreme Court acquitted the appellant, holding that a conviction based on circumstantial evidence must exclude every other reasonable explanation, which this case failed to do: multiple family members, not just the appellant, were present in the house at the time, and prosecution witnesses themselves described the couple's marriage as happy. The Court held that a post-mortem report alone, without a complete and unbroken chain of circumstances pointing only to the accused, cannot sustain a conviction, and that the long unexplained delay in registering the FIR (nearly a year after the death) further weakened the prosecution's case. The impugned judgment was quashed and the appellant was ordered released.
Lesson Learnt
In a case built only on circumstantial evidence, courts cannot convict unless the proven facts rule out every reasonable possibility except the accused's guilt: suspicion and an unexplained medical cause of death are not enough on their own.