The Supreme Court’s 2025 judgment in State of Madhya Pradesh v. Janved Singh revisits a tragic dowry death, restoring the trial court’s conviction and reaffirming how law steps in to uncover truth behind domestic tragedies.
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NEW DELHI: The Supreme Court of India, in its judgment dated October 14, 2025, examined a tragic case of a young woman whose life ended under mysterious circumstances. As the Court poignantly remarked, “The law often steps into homes not to witness celebration, but to lift the veil from grief.”
Case Background
Pushpa, married to Mahesh Singh, faced alleged harassment due to dowry demands. On December 31, 1997, her father-in-law, Janved Singh, reported her death as an accident caused by electrocution while ironing. The Court noted discrepancies: “The post-mortem examination…revealed that the cause of death was asphyxia due to strangulation and burn marks on the body were post-mortem.”
The police charged the accused under Sections 302, 304-B, 498-A, and 201 IPC.
Trial Court Findings
The Sessions Court determined that the electrocution theory was fabricated:
“The theory of electrocution was wholly fabricated and deceased Pushpa’s death was homicidal in nature.”
- Mahesh Singh (husband): Convicted under Sections 304-B and 498-A
- Janved Singh (father-in-law): Convicted under Sections 302, 498-A, and 201, receiving a life sentence.
- Other family members were acquitted.
High Court Ruling
The High Court overturned these convictions, citing issues with the evidence:
Delay in witness testimony:
“Testimonies of PW-2 and PW-19…were recorded after a delay of 6 to 10 months and therefore their credibility was diminished.”
Marriage documentation:
“Lagan Patrika…was seized nearly a year later which lacked the names of bride and groom and was inadmissible.”
Lack of evidence of presence at the scene:
“There was no evidence that Janved Singh was present at the time of scene of occurrence.”
The Court acquitted both accused.
Supreme Court’s Observations
The Supreme Court focused on evidentiary credibility and procedural rigor, reiterating:
“Section 106 of the Evidence Act…is designed to meet exceptional cases in which it would be impossible…for the prosecution to establish facts within the knowledge of the accused which he can prove without any difficulty.”
Ultimately, the Supreme Court upheld the High Court’s acquittal of Janved Singh due to failure to conclusively establish guilt.
The Court concluded that the prosecution successfully proved beyond a reasonable doubt that Janved Singh caused the death of the deceased by strangulation and attempted to cover it up by fabricating an electrocution story.
Consequently, the Supreme Court set aside the High Court’s acquittal and reinstated the Trial Court’s conviction and sentence for Janved Singh, directing that he be taken into custody to serve the remaining term. The appeal was partly allowed.
Section 106, IEA: Burden of Proof
Section 106 assigns the burden of proving certain facts to the person who is in the best position to know them. It applies when a fact is especially within a person’s knowledge, such as in cases of custodial death, dowry death, or alibi. This section is an exception to Section 101 of the IEA.
Objective:
The provision ensures a fair trial by making it easier to prove facts that are accessible to the accused while preventing the prosecution from proving the impossible. It also allows the accused to rebut presumptions derived from a series of facts.
Case Title:
STATE OF MADHYA PRADESH VERSUS JANVED SINGH
CRIMINAL APPEAL NO.460 OF 2014
READ JUDGMENT