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Supreme Court of India 2018-09-19 dismissed

Bhagwat vs State of Maharashtra

Bench: 2 — Navin Sinha

In Brief

A husband was convicted under Section 302 IPC for burning his wife to death on 6 April 2003 in their home. The High Court had acquitted him of dowry-demand charges. The Supreme Court upheld his conviction, finding that post-mortem evidence (burns concentrated on the back and lower limbs rather than front), the absence of cooking fire in the kitchen, testimony from the deceased's sons about his violent, alcohol-fueled behaviour, and his three-month absence from law enforcement all pointed to homicide. The third dying declaration, formally recorded by a judicial magistrate and supported by medical evidence, was preferred over inconsistent earlier statements. The court held that the appellant failed to discharge his burden under Evidence Act Section 106 to explain the death. The conviction stands; the appellant may seek remission after serving approximately 15 years.

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Criminal Law Evidence Dying Declaration Circumstantial Evidence Section 302 IPC Dowry-related Crime Burden of Proof

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