Summary
The Supreme Court upheld the High Court’s reversal of a husband’s acquittal for cruelty and murder of his wife by burning. Consistent evidence from her parents and relatives established repeated ill-treatment and demands for money. The medical, forensic and scene evidence contradicted accidental ignition and, with the surrounding circumstances, proved homicidal death. The convictions and life sentence remained undisturbed.
Issues
- Whether the evidence established cruelty and justified reversal of the acquittal.
- Whether the burning was homicidal or accidental.
- Whether hostile witnesses required rejection of the prosecution case.
Provisions considered
- Section 498A, Explanations (a) and (b), Indian Penal Code, 1860Repeated assault, harassment and demands for money, proved by consistent family evidence, constituted cruelty. (¶¶ 22, 23, 24, 25, 26, 27, 28, 29, 30, 31, 32, 33)
Held
- The parents were natural witnesses to whom the deceased disclosed domestic ill-treatment. Their evidence was corroborated by relatives and withstood cross-examination without material contradiction; there was no basis to discard it on these facts. (¶¶ 22, 23, 25, 28, 29, 30, 31, 32, 33)
- The husband was alone with the deceased when she burned. Kerosene on her body, the kerosene bottle, broken bangles, injury distribution and their strained relationship contradicted the accidental-fire explanation and together established homicide beyond reasonable doubt. (¶¶ 35, 36, 37, 38, 39, 40, 41, 42, 43, 44, 45, 46, 47)
- Some witnesses turning hostile did not undermine the reliable evidence proving the prosecution case. The High Court’s findings of cruelty and murder were affirmed. (¶¶ 48, 49, 50)
Result
Appeal dismissed; High Court convictions under Sections 498A and 302 IPC and life imprisonment upheld.