What this judgment does NOT decide: it does not disturb the acquittal of the other accused of murder under Section 302, nor the acquittal of the three female relatives of all charges, and it lays down no new test beyond applying Sections 106 and 113-B of the Evidence Act to these facts.
- Case
- Ramkishan Digambar Jadhav v. State of Maharashtra
- Court
- Supreme Court of India
- Decision
- Citation
- 2026 INSC 1187
- Bench
- Sandeep Mehta; Devendra Kumar Upadhyaya
- Judgment by
- Sandeep Mehta
- Case numbers
- Criminal Appeal No. 1849 of 2013; Criminal Appeal No. 962 of 2014
- Outcome
- Appeals dismissed; the convictions under Sections 498-A and 304-B and Ramkishan's Section 302 murder conviction stand, and the surviving appellants must surrender within four weeks to serve their remaining sentences. The appeal concerning Digambar abated on his death during pendency.
Supreme Court upholds the murder conviction and life sentence
The Supreme Court has dismissed the appeals of Ramkishan Digambar Jadhav and his co-convicts and upheld the conviction of Ramkishan for the murder of his wife Vimalbai, who died an unnatural death inside the matrimonial home within nine months of their marriage. A bench of Justices Sandeep Mehta and Devendra Kumar Upadhyaya held that Ramkishan, who was in the exclusive company of his wife when she died, had failed to offer a plausible explanation for her death and had instead set up a false defence, which supplied an additional incriminating link completing the chain of circumstantial evidence against him.
The Court also upheld the convictions under Sections 498-A and 304-B read with Section 34 of the Indian Penal Code, cancelled the appellants' bail bonds, and directed the surviving appellants to surrender within four weeks.
A nine-month marriage, dowry demands, and a death at home
Ramkishan married Vimalbai on 12 May 1995. The prosecution alleged that shortly after the marriage she was subjected to continuous harassment and torture at the matrimonial home over unlawful dowry demands: Rs 50,000 in cash, a television set, a tape deck, and a plot of land in the MIDC area at village Ghungrala.
Vimalbai complained to her brother Narayan, the first informant, of beatings, starvation, and once having been tied with a rope and hung in a well with a threat that she would be killed if the demands were not met. In the early hours of 1 February 1996, Ramkishan told Narayan that Vimalbai was experiencing convulsions and was being taken to Naigaon for treatment; her family found her lifeless on the way, and doctors at Naigaon Hospital declared her brought dead.
Narayan's oral complaint at Police Station Naigaon led to Crime No. 11 of 1996 under Sections 302, 498-A and 34. Earlier that morning, Ramkishan had himself reported at the station that his wife had died accidentally, claiming that during sexual intercourse she experienced sudden giddiness, her jaws locked, and she passed away. The police recorded an accidental-death entry, but the post-mortem opined the cause of death as asphyxia due to throttling.
Trial court convictions, and a High Court reversal on murder
Six accused were chargesheeted before the Additional Sessions Judge, Biloli. By judgment dated 21 September 1998, the trial court convicted Ramkishan, his father Digambar and his brother Venkat under Sections 498-A and 304-B read with Section 34, sentencing each to one year's rigorous imprisonment plus a Rs 500 fine for Section 498-A and seven years' rigorous imprisonment for Section 304-B, concurrently. All six accused were acquitted of murder under Section 302 read with Section 34, and the three female relatives were acquitted of all charges.
The three convicts appealed to the Bombay High Court at Aurangabad in Criminal Appeal No. 311 of 1998, while the State appealed in Criminal Appeal No. 395 of 1998 against the murder acquittal. By its common judgment dated 3 July 2013, the High Court dismissed the convicts' appeal and partly allowed the State's appeal: holding Ramkishan's murder acquittal perverse, it set it aside, convicted him under Section 302, and sentenced him to life imprisonment with a fine of Rs 5,000, while maintaining the other accused's acquittal under Section 302 read with Section 34. Ramkishan appealed in Criminal Appeal No. 1849 of 2013 and Digambar and Venkat in Criminal Appeal No. 962 of 2014; Digambar died during pendency, and the appeal abated so far as he was concerned.
The medical evidence contradicted the accidental-death story
The appellants argued that the circumstantial case failed to establish a complete and unbroken chain pointing conclusively to their guilt. Ramkishan maintained that Vimalbai had suffered a sudden epileptic seizure during sexual intercourse, while Digambar and Venkat argued they had been roped in only because of their relationship with Ramkishan, and claimed acquittal on parity with the three acquitted female relatives.
The medical evidence pointed the other way. Dr Shyam Nagapurkar, who with Dr Gunturkar performed the post-mortem, found subcutaneous haemorrhage over the laryngeal area, bruises over the thyroid cartilages, and fracture of the left cornua of the hyoid bone, and opined that the cause of death was asphyxia due to throttling. The medical jurist denied the defence suggestion, noting there was no lock-jaw or displacement of the tongue and that the internal neck injuries could not have been caused by an epileptic fit. The Court found the epilepsy theory false and concocted, as the courts below had.
Section 106: the person in exclusive company must explain
The decisive reasoning turned on Section 106 of the Indian Evidence Act, 1872. None of the accused denied their presence inside the house at the time, and Ramkishan himself said he was with his wife when she went into a seizure. The Court held that, because Vimalbai was in the exclusive company of Ramkishan at the matrimonial home when she met her unnatural death, the statutory burden rested heavily on him to offer a cogent, credible and satisfactory explanation of the circumstances culminating in her death.
Instead of discharging that burden, Ramkishan set up a false defence of an epileptic seizure during sexual intercourse, a plea the medical evidence categorically refuted. The Court held that his failure to furnish a plausible explanation, coupled with the false defence, provided an additional incriminating link that completed the chain of circumstantial evidence and established his guilt for murder under Section 302. The Court drew on Trimukh Maroti Kirkan v. State of Maharashtra: where murder is committed in secrecy inside a house, the inmates bear a corresponding burden under Section 106 to give a cogent explanation of how the crime was committed.
Dowry-death convictions stand; appeals dismissed
The Court also held that the prosecution had duly proved the essential ingredients of Sections 498-A and 304-B read with Section 34. Vimalbai had been married on 12 May 1995 and was strangulated and done to death inside the matrimonial home in the early hours of 1 February 1996, within approximately nine months of marriage, well within the seven-year period under Section 304-B. Her brother Narayan testified to beatings, mental torture and starvation, including the rope-and-well incident; the marriage mediator, her father and two independent neighbours corroborated the persistent harassment over the unmet dowry demands. The appellants failed to rebut the statutory presumption under Section 113-B of the Evidence Act.
The appeals accordingly failed and were dismissed as devoid of merit. With the dismissal, the appellants' bail bonds stood cancelled, and they were directed to surrender before the trial court within four weeks from 2 November 2026 to serve the remaining period of their sentences, failing which the trial court is to secure their arrest, including by issuing non-bailable warrants.
BANTHRY ANALYSISFor law students: why a false explanation can itself incriminate
This judgment is a clean illustration of Section 106 at work. Section 106 does not shift the prosecution's overall burden of proving guilt beyond reasonable doubt; the Court's reasoning starts from facts the prosecution had already established, namely an unnatural, homicidal death inside the home, the accused's admitted presence, and medical evidence of throttling. Only then does the burden of explaining the facts especially within his knowledge fall on the person in exclusive company, and only his failure to discharge it, compounded by a false story the medical evidence refuted, becomes the additional link that completes the chain. Note also the two presumptions side by side: Section 113-B supplied the presumption for the dowry-death charge, while Section 106 supplied the explanatory burden for the murder charge arising from the death in exclusive custody.
READING PROMPTSQuestions for a closer reading
- Why did Section 106 of the Evidence Act place a burden on Ramkishan, and what facts triggered it?
- How did the medical evidence on the cause of death defeat the defence theory of an accidental epileptic death?
- What is the difference between the roles of Section 106 and Section 113-B in this judgment?
