Supreme Court Acquits Sharad Biridhichand Sarda in Cyanide Death Case Citing Reasonable Doubt and Suicide Possibility

After detailed analysis of circumstantial evidence, dying declarations, and medical reports, Supreme Court overturns death sentence, highlighting lack of conclusive proof and admissibility issues of key prosecution evidence

In a landmark judgment delivered on July 19, 1984, the Supreme Court of India acquitted Sharad Biridhichand Sarda, who was earlier convicted and sentenced to death by the Bombay High Court for the alleged murder of his wife, Manju, through potassium cyanide poisoning. The apex court’s decision was grounded in a meticulous reappraisal of the evidence, legal principles governing circumstantial evidence, and the admissibility of dying declarations and letters written by the deceased.

The case revolved around the mysterious death of Manju within four months of her marriage to Sharad Sarda. While the prosecution contended that Sharad, motivated by an illicit affair and ill-treatment of Manju, administered cyanide poison to murder her, the defense asserted that Manju, a highly sensitive and emotional woman, committed suicide due to depression and frustration arising from her marital circumstances.

The Supreme Court examined the letters written by Manju to her sister and friend, which revealed her mental state characterized by deep distress, feelings of loneliness, and a tendency towards suicidal thoughts. These writings indicated that Manju did not complain of immediate threats to her life but expressed profound dissatisfaction and emotional turmoil. The Court also scrutinized oral statements attributed to Manju made to close relatives and friends during her last visit to her parental home. However, the Court held that many such statements were inadmissible under Section 32(1) of the Evidence Act as they lacked proximate relation to the transaction causing her death.

Significantly, the Court highlighted the principle that in cases dependent on circumstantial evidence, the prosecution must establish all links in the chain conclusively to exclude every reasonable hypothesis except guilt. Here, the Court found lapses, particularly noting the prosecution’s failure to prove that Sharad had possession of cyanide and administered it. The Court criticized the High Court for relying on a false defense plea as an additional link in the chain, emphasizing that a weak prosecution case cannot be fortified by the accused’s false plea alone.

Furthermore, the Court found discrepancies and interpolations in the post-mortem report by the medical expert, Dr. Banerji, who initially noted the possibility of suicide but later altered records, raising doubts about the reliability of medical evidence. The behavior and testimonies of key witnesses, including Manju’s parents, were also found to be inconsistent and influenced by emotional bias.

On the question of Sharad’s conduct after Manju’s death, the Court observed that summoning family doctors and informing the police did not align with the behavior of a perpetrator trying to conceal a crime. The Court also noted that the alleged illicit relationship between Sharad and another woman remained unsubstantiated by admissible evidence.

Acknowledging the concurrent findings of the lower courts, the Supreme Court nevertheless held that the High Court committed gross errors of law by ignoring material circumstances favoring the defense and misapplying established legal principles. The Court reiterated the fundamental tenet that where two reasonable views are possible—one favoring the prosecution and the other the accused—the benefit of doubt must go to the accused.

Ultimately, the Supreme Court allowed the appeal, set aside the conviction and death sentence, and ordered the immediate release of Sharad Biridhichand Sarda. The judgment underscores the necessity of rigorous evidence evaluation in capital cases, the cautious application of dying declarations, and adherence to procedural fairness under Section 313 of the Criminal Procedure Code.

Statutory provisions

Constitution of India Article 136, Criminal Procedure Code 1973 Sections 313, 342, Indian Penal Code 1860 Sections 300, 302, 109, 201, 120B, Evidence Act 1872 Sections 3, 8, 32(1), 101-104

Sharad Biridhichand Sarda v. State of Maharashtra, (SC) : Law Finder Doc Id # 90880