The Supreme Court Upholds Husband’s Murder Conviction in a dowry harassment case: when a wife dies an unnatural death while alone with her husband inside the matrimonial home, the Court held, the heavy burden of explaining how it happened falls on him under Section 106 of the Evidence Act.
New Delhi: A husband who offers no credible account of his wife’s unnatural death in the privacy of the matrimonial home cannot expect the prosecution alone to carry the case, the Supreme Court has held, dismissing criminal appeals filed by a husband and two of his relatives from Maharashtra. The Court sustained the husband’s conviction and life sentence for the murder of his wife and the conviction of all three for dowry death and cruelty, and directed them to surrender within four weeks [Ramkishan Digambar Jadhav v. State of Maharashtra].
The judgment, authored by Justice Sandeep Mehta, was delivered on November 2, 2026 by a bench of Justice Sandeep Mehta and Justice Devendra Kumar Upadhyaya.
Silence, and a story the evidence ruled out
The bench stressed that the wife was in the exclusive company of the husband inside the matrimonial home when she died. It held:
“By virtue of Section 106 of the Evidence Act, the statutory burden rested heavily upon the appellant-Ramkishan, who was in the exclusive company and holding custody of his wife [the deceased] in the privacy of the matrimonial home when she met with unnatural death, to offer a cogent, credible, and satisfactory explanation regarding the circumstances culminating into her death.”
The Court relied on its earlier ruling in Trimukh Maroti Kirkan v. State of Maharashtra (2006), which held that the inmates of a house cannot get away by keeping quiet and offering no explanation on the premise that the burden lies entirely on the prosecution.
The husband’s own version was that his wife’s death was accidental, that she suffered a sudden epileptic seizure and giddiness while the two were intimate. The Court found that this version was ruled out by the medical evidence and the post-mortem findings, and that the false explanation itself strengthened the prosecution case:
“The failure of the appellant-Ramkishan to furnish a plausible explanation and in discharging the burden cast upon him by virtue of Section 106 of the Evidence Act coupled with the introduction of a false defence, provides an additional incriminating link that completes the chain of circumstantial evidence, and thereby establishing his guilt for the offence of murder punishable under Section 302 of the IPC.”
How the appeals reached the Supreme Court
The appeals challenged a common judgment dated July 3, 2013 of the Bombay High Court at Aurangabad in Criminal Appeal Nos. 311 and 395 of 1998.
By that judgment, the High Court dismissed the appeal of Ramkishan Digambar Jadhav (accused No. 1), Digambar Narba Jadhav (accused No. 2) and Venkat (accused No. 5), and affirmed their conviction under Sections 498A and 304B read with Section 34 of the Indian Penal Code.
The High Court also partly allowed the State’s appeal. It set aside the trial court’s acquittal of Ramkishan on the murder charge, convicted him under Section 302 IPC for killing his wife, and sentenced him to life imprisonment with a fine of Rs 5,000. The acquittal of accused Nos. 2 to 6 on the murder charge was maintained.
Ramkishan then filed Criminal Appeal No. 1849 of 2013 in the Supreme Court, while his co-convicts Digambar and Venkat filed Criminal Appeal No. 962 of 2014.
Dowry harassment and Section 113B
On the dowry death charge, the Court relied on the testimony of the complainant Narayan (PW-2), who said the deceased complained during visits to her parental home that she was beaten, mentally tortured and starved over dowry demands, and that she was once tied with a rope and lowered into a well with a threat to kill her if the demands were not met.
The Court found this account corroborated by Sambhaji Turatwad (PW-3), who arranged the marriage, by her father Ramrao (PW-4), and by two independent neighbours, Vaijnath Sambhaji Marpatwar (PW-5) and Mahajan Munjaji Yembalwad (PW-6). It concluded that the accused “failed to rebut the statutory presumption under Section 113-B of the Evidence Act and were rightly convicted by the Courts below.”
Surrender within four weeks
Finding no reason to interfere with the High Court’s judgment, the bench dismissed both appeals as devoid of merit. The appellants had been on bail during the appeals. Their bail bonds stand cancelled, and they have been directed to surrender before the trial court within four weeks to serve the rest of their sentences, failing which the trial court will take necessary steps.
Why the judgment matters
The ruling reaffirms a settled principle of criminal law. The prosecution must still prove its case, but when a death happens inside a home and the facts are especially within the knowledge of the person who was there, Section 106 of the Evidence Act (now Section 109 of the Bharatiya Sakshya Adhiniyam) shifts a burden of explanation onto that person. Silence or a false story can then count against the accused.
The judgment also shows how Section 106 and Section 113B work together in dowry cases. Proof of persistent cruelty over dowry raises a presumption of dowry death, while the husband’s failure to explain the death in the matrimonial home becomes an extra link in the chain of circumstantial evidence for murder.
Case Title: Ramkishan Digambar Jadhav v. The State of Maharashtra [Criminal Appeal No. 1849 of 2013, with Criminal Appeal No. 962 of 2014]
Citation: 2026 INSC 1187
Bench: Justice Sandeep Mehta and Justice Devendra Kumar Upadhyaya, Supreme Court of India
Date of Judgment: November 2, 2026
For the Appellants: Senior Advocate Vishwajit Singh with Advocates Shivaji M. Jadhav (AOR), Aditya S. Jadhav, Brij Kishor Sah and others
For the State: Advocates Varad Kilor, Siddharth Dharmadhikari, Aaditya Aniruddha Pande (AOR) and Shrirang B. Varma