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Supreme Court of India 2020-11-19 dismissed

JAYANTILAL VERMA vs STATE OF M.P. (Now Chhattisgarh)

Bench: 2 — Sanjay Kishan Kaul, Hrishikesh Roy

In Brief

A husband was convicted of murdering his wife by strangulation in their matrimonial home. The prosecution relied on testimony from the victim's stepbrother and post-mortem evidence; several witnesses turned hostile. The appellant argued the evidence was insufficient due to few witnesses and lack of direct evidence. The Supreme Court upheld the conviction, holding that the quality—not quantity—of evidence matters. Since the death occurred within the husband's home with only family present, the inmates bore a duty to explain the death under Section 106 of the Evidence Act. The credible testimony and medical evidence of strangulation, combined with the absence of any plausible explanation from the accused, formed a complete circumstantial chain of guilt. The appeal was dismissed."

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Criminal Law Murder Circumstantial Evidence Burden of Proof Strangulation Evidence Act Criminal Procedure Witness Credibility

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