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Supreme Court of India 2021-08-10 allowed

Parubai vs The State of Maharashtra

Bench: 2 — Hemant Gupta, A.S. Bopanna

In Brief

Parubai was convicted by the trial court and High Court for murder (Section 302 IPC) and arson (Section 436 IPC) in connection with a fire that killed her co-wife Mandabai and two children. The Supreme Court found the conviction unsustainable. Although the High Court had discarded the extrajudicial confession and some evidence, it ultimately convicted the appellant based largely on conjecture—primarily that she escaped uninjured, which allegedly proved she caused the fire. The Court held that circumstantial evidence must form a complete chain excluding all innocent hypotheses; suspicion alone is insufficient. The absence of injury, natural human survival instinct, incomplete evidence linking the appellant to kerosene, unproven motive, and lack of corroboration rendered the case one of suspicion, not proof beyond reasonable doubt. The conviction was set aside and the appellant acquitted."

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Criminal Law Murder Circumstantial Evidence Conviction Burden of Proof

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