In Ramkishan Digambar Jadhav v. State of Maharashtra (Criminal Appeal No. 1849 of 2013, 2026 INSC 1187, decided 2 November 2026), the Supreme Court — Sandeep Mehta and Devendra Kumar Upadhyaya, JJ. — dismissed the appeals against a husband’s conviction under Section 302 IPC for the death of his wife, nine months into the marriage, inside the matrimonial home. The judgment is a textbook application of Section 106 of the Evidence Act: where the wife dies an unnatural death in the husband’s exclusive company, the burden of explaining what happened rests on him — and a false explanation, refuted by the medical evidence, becomes an additional link completing the circumstantial chain.
The case in one view
| Case | Ramkishan Digambar Jadhav v. State of Maharashtra, Crl. Appeal No. 1849/2013 (2026 INSC 1187) |
|---|---|
| Bench | Sandeep Mehta and Devendra Kumar Upadhyaya, JJ., Supreme Court of India |
| Decided | 2 November 2026 |
| Provisions | Sections 302, 304-B, 498-A IPC; Sections 106 and 113-B, Evidence Act |
| Outcome | Appeals dismissed; life sentence under Section 302 affirmed; surrender in four weeks |
The background
Vimalbai married Ramkishan in May 1995 and died in the matrimonial home in February 1996 — nine months later — against a backdrop of alleged dowry demands for a television, a tape deck, an industrial plot and Rs 50,000. The husband’s version was that she died accidentally during intercourse following an epileptic seizure. The post-mortem recorded asphyxia due to throttling, and the medical jurist excluded an epileptic fit as the cause of the internal neck injuries. The trial court convicted under Sections 498-A and 304-B but acquitted under Section 302; the Bombay High Court, on the State’s appeal in 2013, convicted under Section 302 and imposed life imprisonment. The matter then waited thirteen years in the Supreme Court.
The Section 106 architecture
The Court’s reasoning follows Trimukh Maroti Kirkan, the touchstone for deaths inside the matrimonial home. The prosecution proved the foundational circumstances: an unnatural death by throttling, inside the home, while the wife was in the husband’s exclusive company. At that point Section 106 of the Evidence Act — whose counterpart is Section 109 of the Bharatiya Sakshya Adhiniyam — placed on the husband the burden of explaining facts especially within his knowledge.
From the judgment: “By virtue of Section 106 of the Evidence Act, the statutory burden rested heavily upon the appellant-Ramkishan” — and his false, medically refuted account “provides an additional incriminating link that completes the chain of circumstantial evidence”.
The false explanation did double duty: it failed to discharge the Section 106 burden, and it became itself a circumstance against him. With consistent witnesses proving dowry-linked cruelty, and the death occurring within seven years of marriage, the unrebutted presumption under Section 113-B sustained the Sections 498-A and 304-B findings as well.
What the decision means in practice
The wider frame
Deaths of young wives inside matrimonial homes present the prosecution’s hardest evidentiary terrain — no eyewitnesses, interested defence narratives, and medical evidence as the only neutral voice. The Section 106 framework, applied consistently from Trimukh Maroti to this judgment, is the law’s structural answer. The case, arising from a 1996 death and finally resolved in 2026, also stands as a sobering marker of criminal appellate timelines: thirty years from death to finality, with the convict on bail for much of it and now directed to surrender.
Frequently Asked Questions
What does Section 106 of the Evidence Act actually do?
It places the burden of proving facts especially within a person's knowledge on that person. In matrimonial-home death cases, following Trimukh Maroti Kirkan, once the prosecution shows the death occurred while the deceased was in the accused's exclusive company, the accused must offer a credible explanation. Section 106 does not relieve the prosecution of its primary burden — it operates once the foundational circumstances are proved. Its counterpart in the new code is Section 109 of the Bharatiya Sakshya Adhiniyam, 2023.
How did the husband's explanation hurt him?
He reported that his wife died accidentally during intercourse following an epileptic seizure. The post-mortem found asphyxia due to throttling, and the medical jurist ruled out an epileptic fit as the cause of the internal neck injuries. A false explanation on a matter only the accused could know became, in the Court's words, an additional incriminating link completing the chain of circumstantial evidence.
Why did the High Court convict when the trial court had acquitted under Section 302?
The trial court convicted under Sections 498-A and 304-B but acquitted under Section 302; on the State's appeal, the Bombay High Court convicted under Section 302 with life imprisonment. The Supreme Court affirmed: the throttling findings, the exclusive-custody circumstance and the false explanation sustained the murder conviction, alongside the dowry-cruelty and dowry-death findings supported by the Section 113-B presumption.
What happens to the convict now?
The appeals were dismissed, the life sentence affirmed, bail bonds cancelled, and the appellant directed to surrender within four weeks, failing which non-bailable warrants would issue. A co-accused's appeal had abated on his death during its pendency.