In the case of Sunil Clifford Daniel vs State Of Punjab on 14 September, 2012, the Supreme Court of India upheld the conviction of Dr. Sunil Clifford Daniel, who was found guilty of murdering his wife, Dr. Loyalla Shagoufta. The case was presided over by Justice B.S. Chauhan and Justice Fakkir Mohamed Kalifulla.
Facts
Dr. Sunil Clifford Daniel and Dr. Loyalla Shagoufta, both qualified doctors, were married on 29th October 1993. However, their relationship became strained, and they started living separately from June 1994. On 9th March 1996, Dr. Daniel handed over a set of blood-stained clothes to the Medical Superintendent of the Christian Medical College (CMC), Hospital Ludhiana, stating that he found them in his room. On the same day, Dr. Shagoufta was reported missing. Her body was found two days later, on 11th March 1996, near a main road in Lalton Kalan, about 20 km away from Ludhiana.
Issues
The main issue in this case was whether Dr. Daniel was guilty of murdering his wife. The prosecution relied heavily on circumstantial evidence, including the blood-stained clothes found in Dr. Daniel’s room, the fact that Dr. Shagoufta was supposed to be on leave during the time of her disappearance, and the recovery of a blood-stained necktie and dumb-bell based on Dr. Daniel’s disclosure statement. The defense argued that the investigation was not conducted fairly and that the evidence was planted.
Court’s Observations
The court observed that the circumstantial evidence pointed towards the guilt of Dr. Daniel. The court noted that Dr. Shagoufta was likely killed in Dr. Daniel’s room, and the blood-stained clothes and other items recovered from his room suggested his involvement in the murder. The court also noted that Dr. Daniel disappeared after the incident and could only be arrested two days later. The court concluded that the chain of circumstances was complete and did not leave any reasonable ground for the conclusion consistent with the innocence of Dr. Daniel.
The court also considered the motive behind the murder. It was noted that the relationship between Dr. Daniel and Dr. Shagoufta was strained, and they were planning to separate soon. The court concluded that there was sufficient motive for Dr. Daniel to kill his wife.
In conclusion, the court upheld the conviction of Dr. Daniel under Sections 302 (punishment for murder) and 201 (causing disappearance of evidence of offence) of the Indian Penal Code, 1860. He was sentenced to life imprisonment and was also ordered to pay a fine.