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Supreme Court of India 2023-10-06 dismissed

BALVIR SINGH vs STATE OF UTTARAKHAND

Bench: 2 — J. B. Pardiwala, Prashant Kumar Mishra

In Brief

Balvir Singh was convicted of murdering his wife, Sudha, by administering poison (Aluminium phosphide) while she was in his exclusive company in Delhi. The High Court upheld the conviction. On appeal to the Supreme Court, the Court held that the prosecution established a prima facie case sufficient to invoke Section 106 of the Evidence Act, shifting the burden to the accused to explain facts within his special knowledge. The husband's failure to offer any credible explanation for the death—despite claiming to have taken his wife to a hospital, without producing supporting evidence—was treated as an additional link in the chain of circumstantial evidence. The Court dismissed both appeals, emphasizing that courts must apply practical reasoning in crimes against women and not allow criminals to escape on procedural grounds. The mother-in-law was convicted only for harassment under Section 498A and her sentence was reduced to time served.

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Criminal Law Evidence Murder Section 302 IPC Section 498A IPC (Dowry Harassment) Section 106 Evidence Act Burden of Proof Circumstantial Evidence Crimes Against Women Poisoning

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