Introduction:

The Allahabad High Court, in Vinay Pratap Singh @ Bablu v. State of Uttar Pradesh (2026 LiveLaw (AB) 506), upheld the conviction and life sentence of a man found guilty of murdering his live-in partner, her mother, and her two minor children. A Division Bench comprising Justice Rajesh Singh Chauhan and Justice Abdhesh Kumar Chaudhary dismissed the criminal appeal, holding that the prosecution had established every incriminating circumstance beyond reasonable doubt and that the chain of circumstantial evidence was complete.

The appellant had been convicted by the Hardoi Trial Court in 2014 under Sections 302, 307 and 404 of the Indian Penal Code, along with Section 3(2)(5) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act. Challenging the conviction, he argued before the High Court that the case rested entirely on circumstantial evidence and that there was no direct eyewitness connecting him to the crime.

According to the prosecution, the deceased, Babita, was an Anganwadi worker who had been residing with her mother and two children after the death of her husband. The appellant had been living with her in a live-in relationship for nearly one and a half years. On the night of 23–24 June 2009, a quarrel allegedly took place between them. The following morning, Babita, her mother, and both children were found dead inside the house with ligature marks around their necks. Post-mortem examinations confirmed that all four deaths were caused by ante-mortem strangulation.

Arguments of the Parties:

The appellant contended that the conviction was unsustainable because the prosecution had failed to produce any direct eyewitness. It was argued that the entire case was based on circumstantial evidence, which did not form a complete chain pointing exclusively towards his guilt. The defence questioned the reliability of the “last seen” theory, disputed the alleged recovery of jewellery and other articles, and submitted that the FIR had been lodged merely on suspicion.

The appellant further claimed that he had been falsely implicated due to a property dispute and argued that the prosecution had failed to establish any credible motive. According to him, the evidence on record was insufficient to exclude every possible hypothesis consistent with his innocence.

The State opposed the appeal by submitting that every circumstance relied upon by the prosecution had been conclusively proved. It argued that witnesses consistently established that the appellant had been residing with the deceased in a live-in relationship and that a serious quarrel had taken place on the night immediately preceding the murders. The prosecution also relied on the recovery of the deceased’s belongings at the instance of the appellant, his conduct after the incident, and the medical evidence to establish an unbroken chain of circumstances leading to his guilt.

Court’s Judgment:

Dismissing the appeal, the Allahabad High Court held that the prosecution had successfully established every link in the chain of circumstantial evidence. The Court found the testimonies of the complainant, the deceased’s sister, and an independent neighbour to be consistent in proving that the appellant had been residing with the deceased for about one and a half years. The neighbour’s testimony regarding the quarrel on the night before the incident and the absence of any evidence showing the appellant leaving the house thereafter further strengthened the prosecution case.

The Bench also noted that the appellant himself admitted during his deposition that he shared an intimate relationship with the deceased and had stayed at her residence on several occasions. This admission corroborated the prosecution’s version regarding their relationship.

The Court found that the prosecution had established a clear motive. Evidence showed that the appellant wanted to marry the deceased, whereas she was unwilling to do so. Frequent disputes also arose because the appellant was allegedly unemployed and financially dependent upon her. These circumstances provided a convincing motive for the crime.

The High Court also relied upon the recovery of jewellery, mobile phones, and other belongings of the deceased from the appellant soon after the incident. These recoveries, coupled with the medical evidence confirming homicidal death by strangulation, constituted significant incriminating circumstances.

A crucial factor considered by the Court was the appellant’s conduct after the occurrence. The Bench observed that despite his close relationship with the deceased and his alleged desire to marry her, he neither informed the police nor participated in the inquest proceedings. The Court held that this conduct was a relevant circumstance under Section 8 of the Indian Evidence Act and strengthened the prosecution case.

Referring to Section 106 of the Indian Evidence Act, the Court held that once the prosecution had established the foundational facts, the burden shifted to the appellant to explain facts that were especially within his knowledge. Since the murders occurred inside the house where the appellant had been residing with the deceased and the prosecution had proved the motive and the last-seen circumstance, the appellant was required to offer a satisfactory explanation. The Court found that he had failed to discharge this burden.

The Bench rejected the plea of false implication due to a property dispute, observing that it remained a mere allegation unsupported by any evidence. It concluded that the circumstances proved by the prosecution were wholly inconsistent with the innocence of the appellant and formed a complete chain leading only to his guilt.

Finding no illegality or perversity in the appreciation of evidence by the Trial Court, the High Court affirmed the conviction and life sentence. The appeal was accordingly dismissed, with the Court holding that the prosecution had proved the appellant’s guilt beyond the pale of doubt and that the evidence left no reasonable possibility of innocence.