- The Punjab and Haryana HC has, while upholding the conviction in a dowry death case titled Vineet vs. State of Haryana held that though motive is significant in deciding an accused's culpability in cases of circumstantial evidence, the same can be dispensed with if the chain of circumstances otherwise links the accused with the crime. In this case, motive can be dispensed with.
- In the instant case, an appeal was filed against the order of conviction passed by the trial Court in a dowry death case. The complainant’s daughter was married to the appellant, however, she was being harassed and pressurized for dowry. The appellant would threaten the victim with death if the dowry demands were not met.
- One day, the complainant received a call from the appellant that her daughter had passed away and that her dead body was lying in a government hospital. Upon receiving this information, the complainant and her husband rushed to the hospital only to find their daughter’s body covered in bruises and upon inquiry, they got to know that the appellant/accused had murdered their daughter by brutally beating her up and poisoning her, in his greed for dowry.
- An FIR was lodged and the accused was booked under section 302 and 498A of IPC. He was convicted by the Additional Sessions Judge and sentenced to imprisonment for life and a fine of 25,000/-. Aggrieved, the appellant/accused moved the HC.
- The Counsel for the appellant argued that the case of the respondents is purely circumstantial in nature and there were major discrepancies between the testimonies of the various witnesses that were produced in support of the prosecution. It was also alleged that there was not a single eyewitness whose evidence could be relied upon, and in the absence of cogent evidence the prosecution’s version of events could not be relied upon.
- It was also alleged that there was no motive for the accused to have committed the said offence, and in its absence a case under section 302 and 498A is not made out.
- The Counsel for the respondents alleged that there was enough evidence on record to show that the appellant was involved in the commission of the offence.
- The Hon’ble HC did not agree with the arguments advanced by the appellant. The Court noted that the mere absence of eye-witnesses is not enough to conclude that the appellant is not guilty of the alleged offence. It was held that the prosecution had been able to establish their case beyond reasonable doubt through the testimonies of the various witnesses that had been brought forth.
- The Court observed that the alleged fact of the victim being poisoned had been corroborated by the medical evidence and the complete chain of events had been established by the prosecution.
- As regards the argument that there was no motive and that the case is purely circumstantial, the Court observed that it had been well established that the motive behind the murder was dowry. The Court also observed that circumstantial evidence is, in no way, inferior to direct evidence and can be the sole basis for conviction in case the chain of events remains unbroken and satisfactorily links the accused with the crime.
- The Court also referred to section 106 of the Indian Evidence Act which states when any particular fact is especially within the knowledge of any person, the burden of proving that fact is upon him. The Court noted that the burden of proving the reason of the death of the victim Preeti was upon the accused, who could not give any reasonable explanation as to the reason why his wife consumed poison or why should he not be held responsible for her murder in light of the circumstances of the case.
- Hence, the appeal was rejected and the sentence passed by the Trial Court was upheld.
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