The Madhya Pradesh High Court, in a significant judgment, dismissed the criminal appeal filed by Smt. Mamta Pathak, upholding her conviction and life imprisonment for the murder of her husband, Dr. Neeraj Pathak. The case, which revolved around circumstantial evidence, highlighted the prosecution's ability to establish guilt beyond reasonable doubt.
Background of the Case
Dr. Neeraj Pathak, a retired Chief Medical Officer, was found dead in his residence at Loknathpuram, Chhatarpur, on May 1, 2021. Initially, the death was reported as accidental electrocution. However, investigations revealed foul play, leading to the arrest of Smt. Mamta Pathak, who was charged under Section 302 of the Indian Penal Code (IPC) for murder.
The prosecution argued that Smt. Mamta Pathak had administered sedatives (Olanzapine tablets) to her husband and later electrocuted him. The trial court convicted her based on circumstantial evidence, including medical reports, witness testimonies, and forensic findings.
Read also:- Delhi High Court Grants Four-Week Parole to Convict for Wife’s Childbirth
Smt. Mamta Pathak’s defense team raised several objections:
Delay in FIR Registration – The FIR was lodged five days after the incident, which the defense claimed was suspicious. However, the court noted that the delay was due to preliminary inquiries under Section 174 CrPC, which is permissible in matrimonial disputes.
Postmortem Report Discrepancies – The defense argued that the postmortem findings were unreliable, citing contradictions in the state of the body (rigor mortis, decomposition). However, the court found no substantial flaws in the medical evidence.
Alleged Coercion in Confession – The defense claimed that her memorandum under Section 27 of the Indian Evidence Act was obtained under duress. The court dismissed this, stating that custody does not require formal arrest, and there was no evidence of coercion.
Motive and Last Seen Theory – The defense denied any motive, asserting that she had a cordial relationship with her husband. However, witness testimonies, including that of Chhandilal Bajpai (PW-4), revealed past disputes and her suspicious conduct, such as traveling to Jhansi without a valid reason immediately after the incident.
Read also:- FIR Quashed by High Court in Mutual Compromise: Legal Insights into Non-Compoundable Cases
The High Court meticulously examined the evidence:
Medical Evidence – The postmortem report confirmed death due to electrocution, with Olanzapine traces found in the viscera. The court rejected claims of natural death due to cardiac issues, noting that the injuries were consistent with electric burns.
Circumstantial Evidence – The prosecution established:
- Smt. Mamta Pathak was the last person seen with the deceased.
- She failed to report his death promptly and fabricated an alibi.
- Recovered evidence (electric wire, sedative strips) corroborated the prosecution’s theory.
Motive – Witnesses testified to marital discord, with evidence of financial disputes and prior incidents of confinement.
Read also:- Supreme Court Rejects SLP in Allahabad Eviction Case, Allows Plea for Extension
The court relied on several landmark judgments:
Sharad Birdhichand Sarda vs. State of Maharashtra – Emphasized that circumstantial evidence must form a complete chain pointing solely to the accused’s guilt.
Sujit Biswas vs. State of Assam – Highlighted the distinction between suspicion and proof beyond reasonable doubt.
Varun Chaudhary vs. State of Rajasthan – Stressed that motive, though not mandatory, strengthens the prosecution’s case.
The High Court concluded:
"The chain of circumstances conclusively proves Smt. Mamta Pathak’s involvement in the murder of Dr. Neeraj Pathak. The defense’s arguments fail to create reasonable doubt, and the trial court’s conviction stands justified."
The court dismissed the appeal, canceled her bail, and directed her to surrender immediately to serve the remaining sentence.
Case Title: Smt. Mamta Pathak vs. The State of Madhya Pradesh
Case No.: Criminal Appeal No. 6016 of 2022
