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Sabitri Samantaray vs The State of Odisha

Criminal Appeal · 2022 INSC 608Decided 20 May 2022
Criminal Appeal No. 988 of 2017
N.V. Ramana · Krishna Murari · Hima Kohli

Background

A husband and wife were tenants of a landlord. One evening, an unknown man was found dead inside their rented portion of the house, having allegedly attacked them; police later found the body had died from strangulation and acid was poured on it to hide identity. The deceased turned out to be a man romantically involved with the couple's daughter. The trial court convicted the couple (and their daughter) for murder; the High Court acquitted the daughter but downgraded the parents' conviction from murder to culpable homicide not amounting to murder, sentencing them to five years' imprisonment.

Decision Breakdown

The Supreme Court examined whether the prosecution had proved its case using circumstantial evidence, given no eyewitness saw the actual killing. It held that where a death occurs in secrecy inside a house, the prosecution's initial burden is lighter, and Section 106 of the Evidence Act then shifts the burden onto the inmates of the house to explain what happened: silence is not an option. The Court found the testimony of the deceased's sister and friends established a credible motive (a soured relationship and a money dispute with the couple's daughter), and medical evidence confirmed homicidal strangulation. Finding no error in the High Court's reasoning, the Supreme Court dismissed both appeals, upheld the conviction under Sections 304(II)/201/34 IPC, and directed the couple to surrender to serve their sentence.

Lesson Learnt

When a crime happens inside a house with only the residents present, the law does not let them stay silent and blame an unexplained stranger, under Section 106 of the Evidence Act, once suspicious circumstances are shown, the occupants must offer a credible explanation, or their silence itself becomes evidence against them.

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

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