The Madhya Pradesh High Court has dismissed an appeal challenging the conviction of the husband under Sections 302 and 498-A IPC, affirming the trial court’s finding that the accused husband was responsible for the homicidal death of his wife by strangulation.
The Division Bench of Justice Vivek Agarwal and Justice Avanindra Kumar Singh held that the death was clearly homicidal, as established by medical evidence showing strangulation leading to asphyxia. The Court found that the accused failed to offer any plausible explanation for the death, which occurred inside the matrimonial home where the couple resided together.
Rejecting the defence of alibi, the Court held that the accused had failed to substantiate it with reliable evidence. It noted that no documentary proof or supporting material was produced, and the plea was raised belatedly, making it unreliable. The Court observed that when an accused raises a plea of alibi, the burden lies heavily on him to establish it with certainty, which was not discharged in the present case.
The Court also considered the testimony of the deceased’s family members regarding dowry demand and cruelty. Addressing arguments on delay in the FIR and alleged defects in the investigation, the Court held that such factors were not sufficient to discredit the prosecution’s case, particularly when supported by medical and circumstantial evidence. It reiterated that lapses in investigation do not automatically result in acquittal if the overall evidence establishes guilt.
On the chain of circumstances, the Court noted that the accused was last present with the deceased and failed to explain the circumstances of her death, which became a strong incriminating factor against him.
Finding no material contradictions or infirmities in the prosecution’s case, the High Court upheld the conviction and directed the accused to undergo the remaining sentence.
Appearance:
Shri Rishabh Singh – Advocate for the appellant.
Shri Manasmani Verma – Govt. Advocate for respondent State.
