Summary

Ravi v. State of Punjab (2025 INSC 170)

Headnotes:

• Murder Trial – Burden of Proof: Prosecution must establish guilt beyond reasonable doubt; hostile witnesses weaken the case.

• Forensic Evidence – Cause of Death: Medical evidence must conclusively establish cause of death to support the prosecution’s case.

• Section 106, Indian Evidence Act: The burden shifts to the accused only when the prosecution establishes a prima facie case.

Detailed Summary:

Ravi was convicted of murdering his first wife by strangulation. The prosecution relied on the testimony of witnesses who later turned hostile, post-mortem findings, and circumstantial evidence. However, the Supreme Court found that the medical report suggested asphyxia but did not conclusively rule out natural causes. The alleged murder weapon, a rope, was not uniquely linked to the crime. Applying the principles of circumstantial evidence, the Court overturned the conviction, holding that the prosecution failed to establish guilt beyond a reasonable doubt. 

• Facts: The accused was convicted of murdering his first wife by strangulation. The prosecution relied on circumstantial evidence, primarily medical reports and hostile witness testimonies.

• Key Arguments:

  • Prosecution: The accused’s presence at the scene, ligature marks on the deceased, and alleged confession to a witness.

  • Defense: Witnesses turned hostile; medical report allowed alternative causes of death (tuberculosis-related asphyxia).

• Supreme Court’s Decision:

  • Failure of Prosecution’s Case:

    • Hostile Witnesses: The primary witnesses, including the deceased’s brother and sister, did not support the prosecution’s version.

    • Uncertain Medical Evidence: The post-mortem report did not conclusively establish strangulation.

    • Unreliable Recovery of Rope: The alleged murder weapon was commonly available, and no forensic confirmation was presented.

  • Application of Section 106, Evidence Act: Since the prosecution did not establish a prima facie case, the burden did not shift to the accused.

• Final Holding: Acquitted due to failure to establish guilt beyond reasonable doubt.