The Supreme Court upheld the conviction under Section 302 IPC, affirming the reliability of a child witness. It ruled that the accused’s mere denial under Section 313 CrPC was insufficient to discharge his burden under Section 106 of the Evidence Act to explain the circumstances of his wife’s death within their home.
Facts Of The Case:
The case involved the murder of Smt. Ranjana by her husband, the accused-appellant Manohar Keshavora Khandate, within their home in Amravati. The prosecution’s case rested primarily on the eyewitness account of their nine-year-old daughter (PW-3). She testified that on the night of the incident, she was sleeping beside her mother when she was awakened by a commotion. She found her father sitting nearby her mother, whose body was covered with a chaddar. The accused instructed her not to remove the covering, claiming her mother was unwell and that he would fetch a doctor, before absconding. Upon removing the chaddar, the child discovered her mother had severe bleeding head injuries and was unresponsive. She immediately alerted their landlord (PW-1), who subsequently informed the police. Post-mortem examination confirmed the homicidal nature of the death caused by blunt force trauma to the head. A significant piece of circumstantial evidence was the recovery of a blood-stained shirt from the accused, which matched the blood group of the deceased. The accused offered a blank denial in his statement under Section 313 CrPC but failed to provide any explanation for the incident.
Procedural History:
The accused-appellant was convicted under Section 302 of the Indian Penal Code and sentenced to life imprisonment by the Additional Sessions Judge, Amravati, on 14th August 2007. His subsequent appeal, Criminal Appeal No. 465 of 2007, was dismissed by the Bombay High Court’s Nagpur Bench, which affirmed the trial court’s judgment on 1st April 2011. The appellant then challenged the High Court’s verdict in the Supreme Court by filing a special leave petition. The Supreme Court, after hearing the appeal, dismissed it on 30th July 2025, upholding the conviction and cancelling the bail granted to the appellant during the pendency of the appeal.
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Court Observation:
The Supreme Court observed that the testimony of the child witness was natural, reliable, and of sterling worth, remaining unshaken during cross-examination. It held that the accused’s mere denial under Section 313 CrPC was an afterthought and insufficient to discharge the specific burden placed upon him by Section 106 of the Indian Evidence Act to explain the circumstances of his wife’s death, which occurred exclusively within the privacy of their matrimonial home. The Court found the child’s account was credibly corroborated by the landlord’s testimony and the forensic evidence of the accused’s blood-stained shirt matching the deceased’s blood group.
Final Decision & Judgement:
The Supreme Court dismissed the appeal and affirmed the life imprisonment conviction under Section 302 IPC. The court cancelled the appellant’s bail and directed him to surrender within four weeks to serve the remainder of his sentence, failing which the trial court was ordered to take appropriate steps to apprehend him.
Case Details:
Case Title: Manohar Keshavrao Khandate vs. State of Maharashtra Citation: 2025 INSC 953 Criminal Appeal No.: Criminal Appeal No. 1021 of 2012 Date of Judgement: July 30, 2025 Judges/Justice Name: Justice Aravind Kumar and Justice Sandeep Mehta
Download The Judgement Here