Inmates of Matrimonial Home Must Explain Unnatural Death of Woman

Source: Supreme Court

Why in News? 

A bench of Justice Sandeep Mehta and Justice Devendra Kumar Upadhyaya of the Supreme Court decided Ramkishan Digambar Jadhav v. State of Maharashtra (2026) on 2nd November 2026. The Court dismissed the appeal and upheld the husband’s conviction for murder under Section 302 of the Indian Penal Code, 1860 (IPC), along with his sentence of life imprisonment.

What was the Background of Ramkishan Digambar Jadhav v. State of Maharashtra (2026) Case? 

• The deceased, Vimalbai, was married to the appellant, Ramkishan. 
• The prosecution’s case was that the accused persons harassed and treated her cruelly over unlawful dowry demands. 
• According to the complainant, Narayan (PW-2), Vimalbai told her family during visits to her parental home that:  
  • the accused beat her, 
  • they tortured her mentally and starved her, and 
  • in one incident she was tied with a rope and lowered into a well, with a threat to kill her if the dowry demands were not met. 
• Vimalbai died an unnatural death in her matrimonial home. At the time, she was alone with the appellant. 
• The appellant’s defence was that her death was an accident. He claimed she had a sudden epileptic seizure and giddiness while they were having sexual intercourse. 
• The Courts below convicted the accused and sentenced them to life imprisonment. 
• The accused then appealed to the Supreme Court. 

Question before the Supreme Court: 

• When a wife dies an unnatural death in the matrimonial home while she is alone with her husband, does Section 106 of the Evidence Act place a burden on the husband to explain how she died? And what happens to the case if he gives no explanation, or a false one?

What were the Court’s Observations? 

On Section 106 of the Indian Evidence Act, 1872: 

• The Court stressed that Vimalbai was alone with the appellant in the matrimonial home when she died an unnatural death. 
• Because the appellant had custody of his wife inside the privacy of the home, Section 106 put a heavy statutory burden on him. He had to give a cogent, credible and satisfactory account of how her death came about. 
• He did not discharge this burden. Instead, he put forward a false and made-up defence of an epileptic seizure, and the medical evidence and post-mortem findings ruled that defence out. 

On the precedent relied upon: 

• The Court relied on Trimukh Maroti Kirkan v. State of Maharashtra (2006), which held that Section 106 places a matching burden on the inmates of a house to explain how a crime committed inside it took place. 
• Inmates cannot stay silent and offer no explanation by arguing that the burden lies entirely on the prosecution. 

On the false defence as an additional link: 

• The appellant failed to give a plausible explanation, and he also raised a false defence. 
• Taken together, these provided an additional incriminating link that completed the chain of circumstantial evidence. This established his guilt for murder under Section 302 of the IPC. 

On the presumption under Section 113B of the Indian Evidence Act, 1872: 

• PW-2 gave clear evidence of persistent harassment and cruelty over dowry demands. 
• His testimony was strongly corroborated by:  
  • Sambhaji Turatwad (PW-3), the mediator who arranged the marriage, 
  • Ramrao (PW-4), the father of the deceased, who confirmed the repeated demands and physical abuse, and 
  • Vaijnath Sambhaji Marpatwar (PW-5) and Mahajan Munjaji Yembalwad (PW-6), two independent neighbours of the deceased’s parental home. 
  • The Court therefore held that the accused had failed to rebut the statutory presumption under Section 113B, and that the Courts below were right to convict them. 

Decision: 

• The appeal was dismissed. 
• The conviction and the sentence of life imprisonment were upheld.

What is Section 109 of the Bharatiya Sakshya Adhiniyam, 2023? 

About: 

• Section 109 of the Bharatiya Sakshya Adhiniyam, 2023 (BSA) deals with the burden of proving a fact that is especially within someone’s knowledge. 
• It says that when a fact is especially within the knowledge of a person, the burden of proving that fact is on that person. 
• It falls under Chapter VII of the BSA, which deals with the burden of proof. 

Illustrations: 

• (a) When a person does an act with an intention different from what the nature and circumstances of the act suggest, that person must prove the intention. 
• (b) A is charged with travelling on a railway without a ticket. A must prove that he had a ticket. 

Key Features: 

• Exception to the general rule: Under Section 104 of the BSA, whoever asserts a fact must prove it. Section 109 is an exception to that general rule. 
• Prosecution’s primary burden remains: Section 109 does not relieve the prosecution of its duty to prove guilt beyond reasonable doubt. It comes into play only after the prosecution has proved the foundational facts. 
• Inmates of the house: When a crime takes place inside a house, out of public view, the people living there are expected to explain how it happened. 
• Silence or a false explanation counts against the accused: If the accused gives no explanation, or a false one, about facts especially within their knowledge, this can serve as an additional link in a chain of circumstantial evidence. It cannot be the only basis for a conviction. 

Section 106 of the Indian Evidence Act, 1872: 

• Section 109 of the BSA is the same as Section 106 of the Indian Evidence Act, 1872 (IEA). The wording and both illustrations are unchanged. 
• Section 106 of the IEA says that when a fact is especially within the knowledge of a person, the burden of proving that fact is on that person. 
• In the present case, the Supreme Court applied Section 106 of the IEA because the incident happened before the BSA came into force. 
• In Trimukh Maroti Kirkan v. State of Maharashtra (2006), the Supreme Court held that Section 106 places a matching burden on the inmates of a house to explain how a crime committed inside it took place. Inmates cannot stay silent and argue that the burden lies entirely on the prosecution.

What is Section 118 of the Bharatiya Sakshya Adhiniyam, 2023? 

About: 

• Section 118 of the BSA deals with the presumption as to dowry death. 
• It applies when the question is whether a person has committed the dowry death of a woman, and it is shown that soon before her death that person subjected her to cruelty or harassment for, or in connection with, a demand for dowry. 
• In such a case, the Court shall presume that the person caused the dowry death. 

Key Features: 

• Mandatory presumption: The words “shall presume” make the presumption compulsory once its foundational facts are proved. The accused can still rebut it. 
• Meaning of dowry death: “Dowry death” has the same meaning as in Section 80 of the Bharatiya Nyaya Sanhita, 2023 (BNS), which was earlier Section 304B of the IPC. 
• “Soon before her death”: There must be a close and live link between the cruelty or harassment and the death. 
• Burden shifts to the accused: Once the prosecution proves the foundational facts, the accused must rebut the presumption. 

Section 113B of the Indian Evidence Act, 1872: 

• Section 118 of the BSA is the same as Section 113B of the IEA. 
• In the present case, the Supreme Court held that the accused had failed to rebut the presumption under Section 113B of the IEA.