The Supreme Court has upheld the conviction of a husband for murdering his wife, holding that the circumstances surrounding his alleged relationship with another woman, coupled with prolonged marital discord, provided a clear motive for the crime.
A bench of Justice Dipankar Datta and Justice Satish Chandra Sharma dismissed the appeals filed by Piyush Shyamdasani, Renu alias Akhilesh Kanaujiya and Sonu Kashyap against their convictions. At the same time, the Court rejected the Uttar Pradesh government’s challenge to the acquittal of Manisha Makhija, who was alleged to be involved in the relationship with the husband.
The Court found that the evidence pointed to a long-standing dispute between the husband and his wife, as well as the wife’s opposition to his relationship with Makhija. These circumstances, the Court held, sufficiently explained the motive behind the murder.
The Court observed that there was no apparent prior enmity or financial motive behind the killing. Against that backdrop, the husband’s strained marriage and his prolonged association with the co-accused provided the most plausible explanation for the crime.
The case arose from an incident in July 2014. According to the prosecution, the husband planned a dinner outing with his wife as part of a larger conspiracy to eliminate her.
The prosecution alleged that the husband remained in frequent contact with the other accused through a SIM card registered in a false name. The plan was allegedly for a group of men to intercept the vehicle while the husband and his wife were returning home.
The assailants were allegedly expected to attack the vehicle, pull the husband out, abduct the wife along with the car and make the incident appear to be a case of abduction. The vehicle was later found abandoned with the woman’s body inside.
The trial court convicted all six accused of offences including murder, abduction, causing disappearance of evidence, giving false information and criminal conspiracy under the Indian Penal Code. The High Court subsequently upheld the convictions but acquitted the alleged paramour for lack of sufficient evidence linking her to the murder conspiracy.
The Supreme Court found that the call detail records established a significant connection between the accused persons.
The Court noted that the accused had remained in regular contact with one another through several numbers, regardless of the names under which those numbers were officially registered. The evidence, it held, sufficiently connected the phone numbers appearing in the call records with the accused persons.
The Court also relied on the failure of the accused to offer a credible explanation for the incriminating circumstances.
Once the prosecution had established a strong connection between the accused persons and the communication network used in the alleged conspiracy, the burden was on the accused to explain facts within their special knowledge. Their denial, without a plausible explanation, was found to strengthen the prosecution case.
However, the Court drew a clear distinction between evidence of a relationship and evidence of participation in murder.
While the unusually high volume of calls between the husband and the alleged paramour could indicate that they were in a relationship, the Court held that this fact alone could not establish that she was part of the conspiracy to kill the deceased.
The Supreme Court also found the husband’s conduct after the incident to be incriminating and concluded that the overall chain of circumstances supported the conviction.
The appeals against the convictions were therefore dismissed, while the acquittal of the alleged paramour was allowed to stand.
