Jagdish Gond vs The State of Chhattisgarh 2025: Supreme Court Case

Jagdish Gond vs The State of Chhattisgarh 2025 case gained attention for its reliance on the “last seen together” theory and interpretation of Section 106 of Indian Evidence Act. It raised important questions about the burden of proof, role of circumstantial evidence and presumption of innocence in criminal trials particularly when domestic deaths occur behind closed doors. Discover more in-depth analyses of important Supreme Court decisions by exploring Recent Judgements of Supreme Court.

Jagdish Gond vs The State of Chhattisgarh 2025 Introduction

The case of Jagdish Gond vs The State of Chhattisgarh 2025 revolves around the suspicious death of a young married woman earlier treated as suicide which later led to the Prosecution of her husband and in-laws. After the Trial Court acquitted all accused but the High Court reversed the husband’s acquittal and convicted him for murder under Section 302 of Indian Penal Code. The husband challenged the conviction before the Supreme Court.

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The case at hand centres around the suspicious death of a young married woman, initially deemed a suicide which later led to the Prosecution of her husband and in-laws. The Trial Court acquitted all three accused and cited lack of evidence and an inconclusive medical report. The High Court convicted the husband under Section 302 of Indian Penal Code relying mainly on the presumption under Section 106 of Indian Evidence Act due to the couple’s cohabitation and the failure of the accused to establish a credible alibi. The following are the facts of Jagdish Gond vs The State of Chhattisgarh -

Background of the Case

The death of a young woman, married for two years occurred under suspicious circumstances. The cause of death was not unequivocally established as murder. The Prosecution initiated legal proceedings against her husband and in-laws.

Incident and Immediate Response

On 29th January, 2017, the husband returned home from work and found his wife lying unresponsive on the cot inside their residence. He immediately informed his parents, who lived nearby and also reported the matter to the Police Station at Mulmula, District Janjgir-Champa. The police registered the case as a sudden and unnatural death under Section 174 of Code of Criminal Procedure, 1973 on the same day. Authorities conducted an inquest and noticed a ligature mark on the front of the deceased’s neck. At that time, no one raised any suspicion regarding the cause of death.

Lodging of Complaint and Arrest

On 3rd February, 2017, the deceased’s father filed a formal complaint. Acting on it, the police registered a First Information Report and arrested the husband along with his parents. The Prosecution filed a charge sheet against them under Section 498A and Section 306 r/w Section 34 of Indian Penal Code and Section 302 r/w Section 34 of Indian Penal Code.

Trial Court Proceedings

The Trial Court examined eight witnesses, including:

• PW-1: Patwari who prepared the site plan
• PW-2: Deceased’s father
• PW-3: Tehsildar who prepared the inquest report
• PW-4: Deceased’s mother
• PW-5: Officer who registered the FIR
• PW-6: Deceased’s cousin
• PW-7: Investigating Officer
• PW-8: Doctor who conducted the postmortem

The Trial Court found no evidence of the involvement of the accused in the woman’s death. The postmortem report indicated a ligature mark on the front of the neck and several fractures on the body. Relying on medical texts and the inconclusive opinion of PW-8 i.e., Doctor. The Court held that the woman had committed suicide and ruled out death by hanging or strangulation. Accordingly, it acquitted all the accused.

High Court Proceedings and Conviction

The State appealed against the acquittal awarded by the Trial Court. However, the High Court upheld the acquittal of the in-laws but convicted the husband under Section 302 IPC and sentenced him to life imprisonment.

The High Court highlighted that the couple lived together and under Section 106 of Indian Evidence Act, 1872, the husband was expected to explain the circumstances surrounding his wife's death. The husband contended that he was on duty at a nearby cement factory on the night of the incident but he failed to produce any evidence to support his alibi. Based solely on the failure of the alibi and fact that the deceased and accused were residing together. Thus, the High Court held the husband guilty of murder. Aggrieved by this, the Husband approached the Supreme Court.

The following issues were addressed in Jagdish Gond vs The State of Chhattisgarh 2025 -

• Whether the mere fact of the husband and wife being last seen together in their shared home is sufficient to convict the husband for murder in the absence of other corroborating evidence?

The Supreme Court examined whether the last seen together theory solely could establish guilt without a complete chain of circumstances or supporting evidence.

• Whether the burden of proving an alibi rests on the accused?

The Court considered whether the High Court was right in placing the burden on the accused to prove his alibi despite the initial claim of absence being communicated early to the police.

• Whether the Prosecution had discharged its burden of proving the guilt of the accused beyond reasonable doubt?

The Court in Jagdish Gond vs The State of Chhattisgarh scrutinized whether the Prosecution successfully disproved the accused’s alibi and established a chain of evidence pointing solely to his guilt.

Jagdish Gond vs The State of Chhattisgarh 2025 Legal Provisions

Section 498A, Section 302 and Section 34 of Indian Penal Code played an important role in Jagdish Gond vs The State of Chhattisgarh 2025. The following are analysis of these provisions 

Section 498A of Indian Penal Code: Husband or relative of husband of a woman subjecting her to cruelty

Section 498A (now Section 85 and Section 86 of the Bharatiya Nyaya Sanhita 2023) states that whoever, being the husband or the relative of the husband of a woman, subjects such woman to cruelty shall be punished with imprisonment for a term which may extend to three years and shall also be liable to fine.

Explanation

• Cruelty includes:

1. Any willful conduct likely to drive the woman to suicide or cause grave injury or danger to her life, limb, or health (mental or physical).
2. Harassment with the intent to coerce the woman or her relatives to meet unlawful demands for property or valuable security, or due to her or her relatives' failure to meet such demands.

Section 302 of Indian Penal Code: Punishment for Murder

Section 302 (Now Section 103 of Bharatiya Nyaya Sanhita 2023) deals with punishment for murder. It states that whoever commits murder shall be punished with death, or imprisonment for life, and shall also be liable to fine.

Section 34 of Indian Penal Code: Common Intention

Section 34 (Now Section 3(5) of Bharatiya Nyaya Sanhita 2023) deals with acts done by several persons in furtherance of common intention. It states that when a criminal act is done by several persons in furtherance of the common intention of all, each of such persons is liable for that act in the same manner as if it were done by him alone.

Jagdish Gond vs The State of Chhattisgarh 2025 Judgment and Impact

On 7th April, 2025, the 2-Judge Bench of the Supreme Court comprising Justice Sudhanshu Dhulia and Justice K. Vinod Chandran in Jagdish Gond vs The State of Chhattisgarh ruled that the mere fact that a husband and wife were last seen together in their shared home does not automatically justify convicting the husband for his wife’s murder especially when he has raised a credible alibi and the Prosecution fails to disprove it.

Observation of the Bench

A Bench of Justices Sudhanshu Dhulia and K. Vinod Chandran reversed the conviction awarded by the High Court. The Supreme Court highlighted that the burden of proving the alibi was wrongly placed on the accused. The Court observed that the husband had already informed the police prior to the FIR that he was on duty at a cement factory when the incident occurred and the police failed to investigate this claim.

Explanation of Legal Position

The Supreme Court in Jagdish Gond vs The State of Chhattisgarh examined that husband's inability to explain the unnatural death of his wife in their shared residence can be an important factor but it cannot be the sole basis for conviction. The accused had provided a plausible explanation of his absence and the police had ample opportunity to verify his presence at the factory which they failed to do.

Criticism of the High Court Reasoning

The Supreme Court condemned the High Court for assuming that it was the husband's responsibility to prove his alibi. It highlighted that the first intimation to the police had clearly mentioned the husband’s absence which made the burden of disproving the alibi rest squarely with the Prosecution.

Lack of Conclusive Evidence

The Court in Jagdish Gond vs The State of Chhattisgarh noted that the Prosecution could not present a complete and unbroken chain of evidence that pointed conclusively to the husband's guilt. It observed that:

• The husband had promptly informed the police about his wife’s unnatural death.
• No suspicion was raised by the deceased’s family at the time of the incident.
• Allegations of cruelty by the husband and in-laws surfaced only five days later and remained largely unsubstantiated.
• There was no evidence placing the husband at the scene during the time of death.

Final Verdict in Jagdish Gond vs The State of Chhattisgarh

On the basis of the above findings, the Supreme Court in Jagdish Gond vs The State of Chhattisgarh held that no incriminating circumstance had been proven against the accused. The Court allowed the criminal appeal and set aside the High Court’s conviction and restored the acquittal granted by the Trial Court. The Court ordered the immediate release of the husband.

Conclusion

In Jagdish Gond vs The State of Chhattisgarh 2025 the Supreme Court on 7th April, 2025 set aside the conviction awarded by the High Court and restored the Trial Court’s acquittal. The Court held that suspicion and cohabitation alone could not substitute for proof beyond reasonable doubt, especially when the prosecution failed to disprove a plausible alibi.