Husband alone with his wife must explain her unnatural death at home, Supreme Court holds on the special knowledge rule

2 November 2026

The Supreme Court has held that when a woman dies an unnatural death inside her matrimonial home and only her husband was with her, he carries a statutory burden to give a cogent, credible and satisfactory explanation of how she died. The ruling came in Ramkishan Digambar Jadhav versus State of Maharashtra, decided by Justices Sandeep Mehta and Devendra Kumar Upadhyaya. The burden flows from Section 106 of the Indian Evidence Act, 1872, now Section 109 of the Bharatiya Sakshya Adhiniyam, 2023, which places the burden of proving a fact especially within a person's knowledge on that person. The Court followed Trimukh Maroti Kirkan versus State of Maharashtra of 2006, which held that members of a household cannot stay silent and rest on the prosecution's burden. The husband's explanation was found to be false and contrary to the medical evidence, and that falsity became an extra incriminating link in the chain of circumstantial evidence. The Court also found the presumption under Section 113B of the Evidence Act unrebutted and upheld the conviction and the life sentence.