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Vijay Nathalal Gohil v. State of Maharashtra

Criminal Appeal · 2019 INSC 993Decided 3 Sept 2019
Criminal Appeal No. 42 of 2010
Justice Indira Banerjee · Justice Sanjiv Khanna

Background

The appellant's wife was found dead in 1990, with the appellant claiming she died by consuming poison. A postmortem instead revealed violent asphyxial death by suffocation, with injuries inconsistent with the appellant's suicide narrative and discrepancies between the panchnama and the doctor's findings. The trial court convicted him of murder under Section 302 IPC (acquitting him of linked dowry-death charges), and the Bombay High Court upheld the murder conviction, leading to this further appeal to the Supreme Court.

Decision Breakdown

The Supreme Court held that although the case rested on circumstantial evidence with no eyewitness, the chain of circumstances, the appellant's admitted presence at the scene, unexplained ante-mortem injuries and nail marks suggesting resistance, the postmortem doctor's medical findings, and the appellant's own admissions under Section 313 Cr.P.C., excluded any reasonable possibility of innocence. Finding the trial court and High Court's concurrent findings of guilt sound, the Court declined to interfere and dismissed the appeal, affirming the life sentence under Section 302 IPC.

Lesson Learnt

A murder conviction can validly rest entirely on circumstantial evidence where the chain of facts is complete and points unerringly to guilt, especially when the accused's own explanation for the death is contradicted by medical evidence.

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

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