The State of Maharashtra vs Gajanan Raghunath Adhav (UTP) Advocate - खरात बी. एच — 155/2023

Case Summary: State of Maharashtra v. Gajanan Raghunath Adhav Court: Sessions Court, Jalna Judge: V.M. Mohite Date: 22 April 2026 Case: SC 155/2023 Decision All eight accused were acquitted of all charges including dowry-related cruelty (§498-A), criminal intimidation (§506), insult (§504), voluntarily causing hurt (§323), murder (§302), causing death by negligence (§304-B), and criminal conspiracy (§120-B) of the Indian Penal Code. Key Facts - Deceased Kavita married accused No.1 (Gajanan) in April 2021 - Prosecution alleged systematic ill-treatment and harassment by the accused and his family members - On 31 December 2022, deceased died in circumstances involving a tractor; accused claimed it was a road accident Critical Findings 1. Weak Evidence on Cruelty: - Prosecution witnesses (brothers of deceased) provided only vague allegations about ill-treatment - No specific dates, instances, or corroborating evidence presented - Deceased herself never lodged formal complaints despite being a government employee - Inconsistencies between testimonies of the two brothers regarding the alleged November 2022 meeting 2. Inconclusive Medical Evidence: - Post-mortem examination could not definitively establish whether death was accidental or homicidal - Doctor admitted injuries could result from a motorcycle fall onto hard objects 3. Unreliable Witness Testimony: - PW-5 (Haridas Sable) claimed deceased phoned him expressing threat to her life, but failed to disclose this fact to family members or police at hospital despite discussions about the incident—suggesting fabrication - PW-6's evidence contradicted PW-5's account about how news of the accident was communicated - Deceased had daily phone contact with her brothers but allegedly called only a distant relative when threatened—deemed improbable 4. Significant Delay in FIR: - Complaint lodged 15+ hours after discovering the body (01 January 2023 at 15:38 hours) - No reasonable explanation for delay - Court noted this delay "proved fatal to the prosecution," allowing time for witnesses to fabricate murder narrative for a road accident 5. Lack of Direct Evidence: - No eyewitness to any alleged murder - Alleged conspiracy between accused No.1 and No.2 based only on phone call records—insufficient to establish criminal agreement - Accused No.1 was also injured and hospitalized for road traffic accident; no injury certificate produced for comparison Legal Principles Applied Court applied the *Sharad Biridhichand Sarda* doctrine on circumstantial evidence, requiring that circumstances must: - Be fully established (not merely suspected) - Be consistent only with guilt - Exclude every reasonable hypothesis except the accused's guilt - Create a complete chain of evidence Conclusion The court found the prosecution failed on all fronts: the alleged cruelty was unsubstantiated, the death's homicidal nature was unproven, and the conspiracy was purely speculative. The court concluded the accused likely lodged a false murder complaint to give "colour of murder to the incident which is purely an accident by giving it a thought." This case analysis is maintained by casestatus.in based on publicly available court records.