Supreme Court Upholds Husband’s Murder Conviction in Matrimonial Home Death Case Under Section 106 Evidence Act
On 21st May, the Supreme Court of India, considering circumstantial evidence and custodial accountability within a matrimonial home, upheld the conviction of a husband for the murder of his wife, holding that his failure to explain the circumstances surrounding her death attracted an adverse inference under Section 106 of the Indian Evidence Act, 1872.
A Bench comprising Justice Pankaj Mithal and Justice Prasanna B. Varale delivered the judgment on May 21, 2026, in Chetan Dashrath Gade v. State of Maharashtra, reported as 2026.
The Court dismissed the appeal filed by the husband and affirmed his conviction under Section 302 of the Indian Penal Code, 1860 for strangulating his wife to death inside their matrimonial home.
Background of the Case
The deceased had married the appellant on April 24, 2012. According to the prosecution, she was subjected to harassment and monetary demands by her husband and in-laws. Evidence before the Court showed that the accused had allegedly demanded ₹1 lakh from the deceased’s family for purchasing a pick-up vehicle, which was eventually paid.
On August 23, 2015, the accused informed his father that the deceased had allegedly attempted suicide by hanging. She was initially taken to a private clinic and thereafter to another hospital, where doctors declared her “brought dead.”
Upon seeing the body, the deceased’s father noticed several suspicious circumstances, including fresh injury marks on her face, ligature marks around her neck, and missing ornaments such as earrings, anklets, and toe rings. Subsequently, an FIR was lodged.
Although the Trial Court acquitted the accused persons of offences under Sections 498A and 304B IPC due to insufficient proof of cruelty and dowry death, the husband was convicted for murder solely on the basis of circumstantial evidence. The conviction was later affirmed by the Bombay High Court.
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Supreme Court’s Findings
The Supreme Court found that the prosecution had successfully established a complete chain of circumstances pointing unerringly toward the guilt of the appellant.
The Bench noted that the death had occurred within the matrimonial home, where the deceased and the accused were residing together. Significantly, the appellant failed to offer any satisfactory explanation during his examination under Section 313 of the Code of Criminal Procedure regarding the circumstances leading to his wife’s death.
The Court observed:
“…the appellant could not displace the burden cast upon him under 106 Indian Evidence Act.”
The Bench further emphasized that once incriminating facts are shown to be especially within the knowledge of the accused, the burden shifts upon him under Section 106 of the Indian Evidence Act, 1872.
Highlighting the importance of the accused’s silence and conduct after the incident, the Court observed:
“…the failure of the appellant (husband) to furnish any plausible explanation in discharge of the burden cast upon him under Section 106 of the Indian Evidence Act, cumulatively form a chain so complete as to leave no reasonable ground for doubt.”
The Court also relied upon settled principles governing conviction based on circumstantial evidence, including the precedent laid down in Sharad Birdhichand Sarda v. State of Maharashtra.
In its detailed analysis, the Bench held:
“…we are of the considered opinion that the prosecution has successfully established a complete and unbroken chain of circumstances which unerringly points towards the guilt of the appellant and is wholly inconsistent with any hypothesis of innocence. The medical evidence, the attending circumstances surrounding the death of the deceased within the matrimonial home, the conduct of the appellant subsequent to the incident, the false defence sought to be projected through the alleged suicide note, and the failure of the appellant to furnish any plausible explanation in discharge of the burden cast upon him under Section 106 of the Indian Evidence Act, cumulatively form a chain so complete as to leave no reasonable ground for doubt.
The principles governing conviction on circumstantial evidence as enunciated in Sharad Birdhichand Sarda (Supra) stand fully satisfied in the facts of the present case.”
Accordingly, the Supreme Court dismissed the appeal and upheld the conviction of the husband for murder under Section 302 IPC.
Legal Significance of the Judgment
The ruling reiterates the settled principle that in cases involving deaths inside the matrimonial home, where crucial facts are within the exclusive knowledge of the accused spouse, the burden under Section 106 of the Indian Evidence Act assumes considerable importance.
The judgment also reinforces that conviction can safely rest on circumstantial evidence when the prosecution establishes a complete and unbroken chain of incriminating circumstances inconsistent with the innocence of the accused.
Case Details
- Case Title: Chetan Dashrath Gade v. State of Maharashtra
- Court: Supreme Court of India
- Bench: Justice Pankaj Mithal and Justice Prasanna B. Varale
- Date of Judgment: May 21, 2026
- Citation: 2026 LiveLaw (SC) 526
- Statutory Provisions Involved: Section 302 IPC, Sections 498A & 304B IPC, Section 106 of the Indian Evidence Act, 1872, Section 313 Cr.P.C.
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