Husband’s Murder Conspiracy Proved Through Call Records, Fake SIMs and False Abduction Story; Mere Affair Cannot Establish Paramour’s Complicity: Supreme Court
Case Name: Piyush Shyamdasani v. State of Uttar Pradesh
Date of Judgment: 20 July 2026
Citation: 2026 INSC 721
Bench: Justice Dipankar Datta and Justice Satish Chandra Sharma
Held: The Supreme Court held that a conviction based on circumstantial evidence may be sustained where call detail records, mobile-location data, recoveries and the accused’s pre- and post-offence conduct form a complete and consistent chain pointing exclusively towards guilt. Where incriminating facts lie within the accused’s personal knowledge, failure to offer a plausible explanation may justify an adverse inference. The Court also clarified that Section 34 IPC does not require the accused’s physical presence at the scene; active participation in furtherance of the common intention, including participation from behind the scenes, is sufficient. However, frequent telephone calls or proof of an intimate relationship, without evidence connecting the person to the assailants or execution of the offence, cannot establish participation in a murder conspiracy.
Summary: The prosecution alleged that Piyush Shyamdasani conspired with hired assailants to murder his wife, Jyoti Shyamdasani, amid a strained marriage and his alleged relationship with neighbour Manisha Makhija. He took his wife to a restaurant and remained in constant telephonic contact with the other accused. After leaving the restaurant, the assailants took control of the car and later murdered her. Piyush subsequently lodged a false complaint alleging that unknown persons had assaulted him and abducted his wife.
The Supreme Court found that the call detail records and mobile-location evidence established continuous coordination among Piyush and the assailants before and during the incident. The accused were using SIM cards registered in other persons’ names, and the relevant phones were recovered from them or at their instance. Their failure to explain these incriminating circumstances strengthened the prosecution case.
Piyush’s subsequent conduct was also found highly incriminating. Contrary to his claim of being attacked, neither he nor the car bore any injury or damage. He left the hospital before medical examination and delayed approaching the police for approximately one hour, enabling the assailants to complete the crime without intervention. Recoveries of blood-stained articles, knives, the deceased’s jewellery and mobile phones further completed the chain of circumstances.
The Court rejected the argument that Section 141 IPC should have been applied merely because the overall conspiracy involved more than five persons. Only four assailants physically committed the murder, while Piyush participated behind the scenes. Section 34 IPC was therefore properly invoked because common intention requires active participation, not necessarily physical presence.
However, the Court affirmed Manisha Makhija’s acquittal. Although the unusually high number of calls exchanged with Piyush could indicate a relationship, there was no evidence connecting her with the assailants or showing that she participated in the plan to kill the deceased. The circumstantial chain against her was therefore incomplete.
Decision: The Supreme Court upheld the convictions of Piyush Shyamdasani, Renu @ Akhilesh Kanaujiya and Sonu Kashyap and directed them to surrender within one week if not already in custody. The State’s appeal against Manisha Makhija’s acquittal was dismissed.