Reversal of acquittal requires demonstrating manifest illegality or perversity in the Trial Court’s findings (Para 6). Section 106 of the Indian Evidence Act cannot substitute for lack of evidence; the accused’s plausible explanation (alibi) must be disproved by the prosecution (Para 9–10). Suspicion, however strong, cannot replace proof in criminal cases (Para 10, citing Sharad Birdhichand Sarda v. State of Maharashtra).

The Supreme Court restored the Trial Court’s acquittal, holding: No unbroken chain of circumstances proved homicide (Para 13). The High Court erred in relying solely on Section 106 without corroborative evidence (Para 9). The medical report did not conclusively establish strangulation or homicide (Para 11).

Major Acts:

• Indian Penal Code, 1860 (IPC) – Sections 302 (Murder), 498A (Cruelty by Husband or Relatives), 306 (Abetment of Suicide), 34 (Acts Done by Several Persons in Furtherance of Common Intention).

• Indian Evidence Act, 1872 – Section 106 (Burden of Proving Facts Especially Within Knowledge).

• Code of Criminal Procedure, 1973 (CrPC) – Section 174 (Inquiry into Cause of Unnatural Death).

1. Nature of Litigation:

   • Criminal Appeal against the High Court’s reversal of the Trial Court’s acquittal, convicting the husband under Section 302 IPC for the alleged murder of his wife.

2. Question of Law:

   • Whether the High Court erred in reversing the acquittal despite the absence of a conclusive chain of circumstances proving guilt beyond reasonable doubt.

   • Whether the presumption under Section 106 of the Indian Evidence Act could singularly establish guilt without corroborative evidence.

3. Facts:

   • The deceased, married for two years, was found dead in her matrimonial home. The husband reported the death, stating he was at work during the incident.

   • The Trial Court acquitted all accused, citing suicide as the cause of death. The High Court convicted the husband under Section 302 IPC, disbelieving his alibi.

4. Submissions/Arguments:

   • Prosecution: Relied on Section 106 of the Indian Evidence Act, arguing the husband failed to explain his wife’s death.

   • Defense: Highlighted lack of medical evidence confirming homicide, inconsistencies in witness testimonies, and the husband’s prompt reporting of the death.

Subjects:

Acquittal reversal, Chain of circumstances, Section 106 Indian Evidence Act, Homicide, Alibi, Medical evidence, Burden of proof.

Latin terms: alibi (explanation of absence), ante mortem (before death).