Conviction based on strong circumstantial evidence including prior cruelty, financial demands, and unexplained absence under Section 106 of Evidence Act
In a significant judgment dated October 6, 2026, the Tripura High Court (Division Bench) upheld the conviction and life sentence of Shri Prasanta Deb @ Raju for the murder of his wife, Sumi Deb alias Maya, inside their matrimonial home. The accused was found guilty under Section 302 of the Indian Penal Code (IPC) for causing homicidal death by manual strangulation.
The case originated from a complaint lodged by the deceased's brother, Maran Nama, stating that Sumi died under suspicious circumstances in her matrimonial house on the night of March 14, 2010. Sumi's family alleged persistent cruelty and monetary demands by the husband and his mother, Ratna Deb, leading to physical assaults, including a severe head injury previously documented.
The prosecution's case was built on circumstantial evidence, with 27 witnesses examined. Neighbours and relatives consistently testified about the strained marital relationship, frequent quarrels, and repeated torture inflicted on the deceased by the accused, especially under the influence of liquor. Importantly, neighbours heard the couple quarrelling on the night before the death, and the deceased was found taking shelter at a neighbour's house after escaping the abuse temporarily.
Medical evidence played a crucial role, with the post-mortem report by Dr. Ranjit Kumar Das confirming abrasions on the neck and lacerations consistent with manual strangulation, resulting in asphyxia. The doctor's expert opinion, unchallenged during cross-examination, conclusively established the homicidal nature of the death.
A vital factor in the judgment was the application of Section 106 of the Evidence Act, which places the burden of explaining facts within the special knowledge of the accused. The court noted that the accused failed to provide any explanation about how the deceased died inside their private residence. His absence from the scene until the arrival of the police and the inability to rebut the circumstantial evidence formed an additional link in the chain proving guilt.
The defence counsel argued that there was no direct eyewitness to the murder and that the evidence was largely hearsay and inconsistent. However, the court rejected these submissions, emphasizing that the totality of the circumstantial evidence, including motive, prior cruelty, medical opinion, and failure to explain, left no reasonable doubt about the accused's guilt.
Quoting from various Supreme Court precedents, the court reiterated that circumstantial evidence must establish an unbroken chain of facts pointing only to the accused's guilt, which was satisfactorily done in this case. The judgment also highlighted that strong suspicion cannot replace proof beyond reasonable doubt, but here, the prosecution's evidence was cogent and credible.
The appeal filed by the accused challenging the conviction and sentence was dismissed, affirming the life imprisonment and fine imposed by the trial court.
This verdict reinforces the judiciary's stance against domestic cruelty and the use of circumstantial and medical evidence in solving such sensitive criminal cases, ensuring justice for victims who suffer in private spaces.
Bottom Line:
Circumstantial evidence - Wife found dead inside matrimonial home - Medical evidence proving homicidal death by manual strangulation - Evidence of prior cruelty, demand of money, quarrel on previous night and unexplained absence of husband from house - Failure of husband to explain circumstances of death within special knowledge under Section 106 Evidence Act provides additional link - Conviction under Section 302 IPC upheld.
Statutory provision(s):
Indian Penal Code Sections 302, 498A, 34; Evidence Act Sections 45, 106; Code of Criminal Procedure Section 313
Shri Prasanta Deb @ Raju v. State of Tripura, (Tripura)(DB) : Law Finder Doc Id # 2995407
