Wife’s Unnatural Death Inside Matrimonial Home Can Sustain Murder Conviction When Husband Gives No Plausible Explanation

Case Name: Chetan Dashrath Gade v. The State of Maharashtra

Citation: 2026 INSC 522

Date of Judgment/Order: 21 May 2026

Bench: Justice Pankaj Mithal and Justice Prasanna B. Varale

Held: The Supreme Court held that in a case based on circumstantial evidence, where a wife dies an unnatural death inside the matrimonial home and the prosecution establishes circumstances pointing to homicidal death, the husband’s failure to offer a plausible explanation under Section 106 of the Indian Evidence Act becomes an additional link in the chain of circumstances. The Court reiterated that absence of motive is not fatal where the facts clearly establish guilt and the chain of circumstances is complete. The Court further held that when medical evidence, injuries, missing ornaments, conduct after the incident and a false suicide defence collectively rule out suicide and point towards strangulation, conviction under Sections 302 and 201 IPC can be sustained.

Summary: The appellant was convicted for murdering his wife Rupali, who died inside her matrimonial home in suspicious circumstances. The prosecution alleged that although the defence projected suicide by hanging, the medical evidence showed asphyxia due to strangulation, fracture of hyoid bone and trachea, ligature marks, injury on the cheek, and other circumstances inconsistent with simple hanging. The deceased’s father also noticed that her earring, anklet and toe-rings were missing, which the Trial Court and High Court treated as a strong circumstance suggesting struggle and strangulation rather than suicide. The appellant first took the body to one private clinic where she was declared dead, but instead of taking her to a civil hospital as advised, took her to another private hospital, and failed to give any satisfactory explanation. The Trial Court convicted the appellant under Sections 302 and 201 IPC while acquitting the accused of dowry-related charges, and the High Court affirmed his conviction. The Supreme Court held that the prosecution had proved a complete chain of circumstances consistent only with the appellant’s guilt, and that the appellant’s failure to explain facts within his special knowledge strengthened the prosecution case.

Decision: The Supreme Court dismissed the appeal and upheld the conviction and sentence imposed on the appellant under Sections 302 and 201 IPC, as affirmed by the Bombay High Court. The Court held that there was no perversity, illegality or miscarriage of justice in the concurrent appreciation of evidence by the Trial Court and the High Court warranting interference under Article 136 of the Constitution. The appellant was, however, granted liberty to submit an application for premature release as per the applicable State policy, with a direction that such application, if submitted, be considered in accordance with the prevailing policy. Pending applications were disposed of.