Chetan Dashrath Gade v. State of Maharashtra, 2026

The deceased married the appellant on April 24, 2012.

The prosecution alleged that the deceased was subjected to harassment and demands for gold and money after marriage.

According to the deceased’s father, the accused demanded Rs. 1 lakh for purchasing a pick-up vehicle.

The complainant’s family later paid the demanded amount to the accused.

On August 23, 2015, the accused informed his father that the deceased had allegedly attempted suicide by hanging.

The deceased was initially taken to a private clinic and later shifted to another hospital where she was declared “brought dead.”

When the deceased’s father saw the body, he noticed fresh facial injuries, ligature marks around the neck, and missing ornaments.

An FIR was subsequently registered against the accused persons.

The Trial Court acquitted the accused persons of offences under Sections 498A and 304B IPC due to insufficient proof regarding cruelty and dowry death.

However, the husband was convicted for murder under Section 302 IPC solely on the basis of circumstantial evidence.

The Bombay High Court affirmed the conviction, after which the matter reached the Supreme Court through appeal.

The Supreme Court dismissed the appeal and upheld the conviction of the husband for murder.

The Court held that the prosecution had successfully established a complete and unbroken chain of circumstances pointing towards the guilt of the accused.

The bench observed that the death occurred inside the matrimonial home, making the surrounding circumstances especially within the knowledge of the husband.

The Court noted that the accused failed to provide any satisfactory explanation during his examination under Section 313 Cr.P.C. regarding the injuries, missing ornaments, and circumstances leading to the death.

The Court held that the appellant failed to discharge the burden cast upon him under Section 106 of the Indian Evidence Act.

The bench relied upon medical evidence, surrounding circumstances, conduct of the accused after the incident, and the false defence projected through the alleged suicide note.

The Court observed that the prosecution evidence was wholly inconsistent with any hypothesis of innocence.

The Supreme Court further held that the principles governing conviction based on circumstantial evidence laid down in Sharad Birdhichand Sarda were fully satisfied.

Consequently, the conviction and sentence imposed upon the husband were affirmed.

The judgment strongly reinforces the evidentiary principle embodied in Section 106 of the Indian Evidence Act.

The Supreme Court clarified that where crucial facts are especially within the knowledge of the accused, silence or false explanation may become an important incriminating circumstance.

The ruling is significant because crimes committed inside the matrimonial home often lack direct eyewitnesses and depend heavily upon circumstantial evidence.

By relying upon medical evidence, conduct of the accused, and inconsistencies in the defence version, the Court ensured a balanced application of criminal jurisprudence.

The judgment reaffirms that conviction based on circumstantial evidence is permissible when every link in the chain points exclusively towards guilt.

The Court appropriately applied the principles laid down in Sharad Birdhichand Sarda, which remains a leading precedent governing circumstantial evidence.

The ruling also highlights the importance of truthful disclosure by the accused when facts are exclusively within personal knowledge.

The decision strengthens accountability in matrimonial offences involving suspicious deaths within the household.

The judgment serves as an important precedent for future murder trials based predominantly on circumstantial evidence.

Overall, the ruling reinforces both the doctrine of adverse inference under Section 106 and the evidentiary value of circumstantial proof in criminal trials.