The main issues in the case of shivaji chintappa patil vs state of maharashtra are murder and the significance of circumstantial evidence in establishing an accused person’s guilt. According to section 302 of the indian penal code, 1860, a person convicted of murder faces a life sentence in prison or the death penalty in addition to a fine. In order to ascertain the accused’s liability for the hanging of his wife, this section was mainly examined under this statute in conjunction with the provisions of the Indian Evidence Act of 1872 and the Code of Criminal Procedure of 1973. The Court also sought to determine who was responsible for hanging suicides as well as homicides in circumstances where the deceased did so.
shivaji chintappa patil vs state of maharashtra Case Facts
- The accused and Jayashree (Deceased) were married for around eight or nine years prior to the incident date.
- Two problems were a blessing for them. The deceased’s mother, Anandibai, and the appellant’s brother, Ramchandra Chintappa, lived apart in different parts of the same home. The deceased and the accused slept in their home on the terrible night of March 23, 2003.
- Ramchandra Chintappa called the appellant at the crack of dawn on March 24, 2003, telling them to report to their field to harvest jawar crop. Opening the door, the accused said that Jayashree had hanged herself and that he was unable to go with him to the field.
- Both Ramchandra Shankar and Ramchandra Chintappa live close to the appellant’s residence. R. Shankar was notified about the incident by R. Chintappa. R. Chintappa visited the village of Panumbre to notify the deceased’s mother and other family members about the occurrence.
- He also went to the Kokrud Police Station to provide information regarding the deceased’s passing. Ad No.13/2003 was originally registered based on the information that was obtained from him.
- Crimes were then recorded for the offense covered by section 302 of the indian penal code. According to the advance death certificate, strangulation-related asphyxia was the most likely cause of death.
- The charge sheet was submitted to the First Class Magistrate, who oversees the jurisdiction. The informed Sessions Judge was assigned the case. After the trial, the learned trial judge found the accused guilty of the section 302 of the indian penal code prohibited offence and handed down a life sentence.
- The appellant filed an appeal with the High Court after feeling wronged by this, but it was ultimately dismissed.
shivaji chintappa patil vs state of maharashtra Issues
- If there is no circumstantial evidence, would the appellant in this instance be held accountable for murder according to Section 302 of the Indian Penal Code, 1860?
Contentions by the Parties
Prosecution:
- The prosecution argued that verification of the concurrent conclusions of the Trial Court and the High Court does not require additional intervention. These courts properly cited the State of Rajasthan v. Kashi Ram case in finding the accused guilty of murder.
- The following five principles were established by the court in the Sharad Birdhichand Sarda v. State of Maharashtra case, which serves as the foundation for the legislation pertaining to convictions based on circumstantial evidence:
- The circumstances that lead to guilt must be proven beyond a reasonable doubt.
- The established facts ought to align with the theory positing the accused’s guilt.
- Situations need to have a decisive quality and tendency.
- All other hypotheses must be ruled out in favour of the one that has to be proven.
- For there to be no plausible basis for a conclusion that supports the accused’s innocence, the chain of evidence must be entirely present.
Defence:
- The appellant’s attorney’s main argument was that the prosecution had not proven the death was homicidal beyond a reasonable doubt. It is not possible to find the appellant guilty of murder based only on circumstantial evidence.
- The appellant’s attorney further argued that there would be no burden essentially on the defense or accused under section 106 of the indian evidence act of 1872, i.e., that there would not be a shift in burden from the prosecution to the accused in such circumstances, citing the case of Subramaniam v. State of Tamil Nadu.
- Furthermore, the appellant contended, citing Babu v. State of Kerala as support, that in circumstances requiring circumstantial evidence, the motive of the person accused of the crime is crucial. In this instance, the prosecution was unable to even determine the accused’s motivation.
- Finally, it was argued that the advantage should go to the accused in cases when both probable outcomes, acquittal and conviction, in accordance with the ratio established in the case of Devi Lal v. State of Rajasthan.
shivaji chintappa patil vs state of maharashtra Judgment
- In this case, the first thing to figure out was whether the hanging was a homicidal act involving the appellant or suicide, meaning it was done by the deceased herself.
- Following the doctor’s submission of the interim report, a post-mortem report was also filed, indicating that “asphyxia due to strangulation” was the cause of death. Marks above the ear are present in both suicide and homicidal cases of hanging.
- In these situations, if the suicide was considered homicidal in nature, the deceased individual would have likely shown some sort of physical resistance, implying violence or fight. However, in this instance, there were no indications of aggression of any kind from any other third party. Following this series of events, the Supreme Court concluded that the hanging was not homicidal in nature.
- The second query concerned the applicability of Indian Evidence Act of 1872, Section 106. According to section 106 of the indian evidence act of 1872, it is the responsibility of the individual to prove any fact, especially one that they are aware of. It is not possible to assume this awareness of the fact simply by being the husband. The Court concluded in the case of Gargi v. State of Haryana that the assumption of guilt on the part of the husband in killing his wife cannot be established by the accused’s simple proximity with the deceased wife.
- Furthermore, the court held in Sawal Das v. State of Bihar that the prosecution’s burden of proving the offence beyond a reasonable doubt cannot be discharged by the use of Sections 103 as well as 106 of the Indian Evidence Act. The accused can only then be given the burden of proof. Therefore, even though they live together or the person was the last person seen with the deceased, the Supreme Court ruled that neither Section 103 nor Section 106 is claimed to work directly against either of the spouses in case of the other’s murder. Furthermore, for the same reasons that the prosecution was unable to establish the death’s homicidal nature beyond a reasonable doubt, the conviction ought to be overturned.
- The third point posed to the Court was whether the appellant would be subject to prosecution under Section 313 of the 1973 Code of Criminal Procedure in the event that they were unable to furnish a sufficient justification in the form of a statement. It is a well-established legal principle that any incorrect explanation may also be used as extra circumstantial evidence, but only after the prosecution has demonstrated that the circumstances as they stand point only to the accused’s guilt.
- Furthermore, motive is crucial to the chain’s completion even in cases where circumstantial evidence has been heavily relied upon. In this case, the prosecution sought to establish the appellant’s motivation for torturing his wife in order to extract money from her mother. The appellant and dead were staying together at the same location for about four days before to the occurrence, indicating cordial connections, thus the Court decided not to rely on any sort of uncorroborated evidence. The material had not even been explicitly admitted by the District Court.
- Since motive is a crucial factor in determining whether circumstantial evidence is admissible, the prosecution was unable to establish its guilt beyond a reasonable doubt. Therefore, in this instance, the final piece needed to complete the chain of events is completely missing. In order to demonstrate that non-explanation under section 313 of the crpc was only used as an extra link to support the findings and the Supreme Court in this decision also cited the Kashi Ram case, although not as a link to finish the chain. But in this instance, the prosecution was completing the chain using completely irrational circumstantial evidence.
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