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Supreme Court of India 2022-05-20 dismissed

BIDYADHAR PRAHARAJ vs STATE OF ODISHA

Bench: 3 — N.V. Ramana, Krishna Murari, Hima Kohli

In Brief

Bidyadhar Praharaj and Sabitri Samantaray were convicted of killing Sanjay Rana, who was in a relationship with their daughter. The trial court convicted them under IPC Sections 302 and 201; the High Court modified this to Section 304(II). On appeal, the Supreme Court upheld the conviction, finding a cogent chain of circumstantial evidence: the appellants were alone in the house when the deceased died, a clear motive existed (the deceased had lent money to their daughter), medical evidence showed homicidal strangulation by multiple persons, and the appellants offered no credible defense. The Court held Section 106 of the Evidence Act rightly applied, placing the burden on the appellants to explain the death. The appeals were dismissed and the appellants were ordered to surrender within two weeks.

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Criminal Law Evidence Law Circumstantial Evidence Murder Section 106 Evidence Act Burden of Proof Homicide

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