Allahabad High Court Upholds Life Sentence for Husband in Wife's Murder Case

Court affirms conviction based on circumstantial evidence, highlighting "last seen theory" and lack of plausible explanation by the accused.

In a significant ruling, the Allahabad High Court has upheld the life sentence of Jitendra Pal, convicted for the murder of his wife, Anita Pal, in a case that heavily relied on circumstantial evidence. The Division Bench at Lucknow, comprising Justices Rajesh Singh Chauhan and Abdhesh Kumar Chaudhary, delivered the verdict on November 27, 2025, confirming the lower court's decision from August 2017.

The case revolved around the murder of Anita Pal, whose body was discovered in a wheat field in Unnao district, with signs of strangulation. The prosecution's case, built on circumstantial evidence, included the "last seen theory," the recovery of broken bangles, and call detail records (CDR) that placed Jitendra Pal near the crime scene on the relevant date. Despite minor discrepancies in witness testimonies, the court held that the chain of circumstantial evidence was complete and pointed unerringly towards Jitendra Pal's guilt.

The judgment highlights the importance of the accused's explanation under Section 313 of the Criminal Procedure Code. Jitendra Pal's failure to provide a credible explanation for the incriminating circumstances, along with his evasive answers, was used as an additional link in the chain of evidence against him. The court also noted the absence of alternative motives like robbery or sexual assault, strengthening the prosecution's case.

The defense argued that the evidence was insufficient and that the prosecution failed to establish a motive, but the court found that the absence of motive was not fatal when other circumstantial evidence was cogent and convincing. The court emphasized that the burden of proof in such cases lies with the prosecution, but the accused's lack of explanation can be considered against him.

In its detailed judgment, the court referred to several precedents, including the landmark case of Sharad Birdhichand Sharda v. State of Maharashtra, reiterating the principles guiding convictions based on circumstantial evidence. The court concluded that the prosecution had successfully established the appellant's guilt beyond reasonable doubt, ruling out the possibility of any other person being responsible for Anita Pal's death.

The decision reinforces the legal standards for convictions in cases relying on circumstantial evidence, underscoring the necessity for a complete and unbroken chain of evidence that points solely to the accused's guilt.

Bottom Line:

Conviction based on circumstantial evidence upheld where "last seen theory," motive, recovery of incriminating materials, and lack of explanation by the accused collectively establish guilt beyond reasonable doubt.

Statutory provision(s): Indian Penal Code, 1860 Section 302, Indian Evidence Act, 1872 Sections 106 and 8, Cr.P.C. Section 313, Section 374(2) Cr.P.C., Section 386 Cr.P.C.

Jitendra Pal v. State of U.P., (Allahabad)(Lucknow)(DB) : Law Finder Doc Id # 2817062