Manohar Keshavrao Khandate vs State of Maharashtra 2025 INSC 953 - Murder Conviction - Child Witness Testimony

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Indian Evidence Act 1872 - Section 106 - While upholding conviction of murder accused, SC observed: The child witness had no reason whatsoever to give false evidence implicating her own father for the murder of her mother. The bald plea of denial advanced by the accused-appellant in his statement under Section 313 CrPC, is clearly an after-thought and insufficient to discharge the burden cast upon him by Section 106 of the Evidence Act. (Para 10) In terms of Section 106 of the Evidence Act, the burden rested upon the accused- to offer a credible explanation as to under what circumstances the deceased , sustained the fatal injuries, particularly when the incident took place within the four walls of the house where the accused- resided with the deceased (Para 14)

Case Info


Case Name and Neutral Citation

  • Case Name: Manohar Keshavrao Khandate v. State of Maharashtra
  • Neutral Citation: 2025 INSC 953

Coram (Judges)

  • Justice Aravind Kumar
  • Justice Sandeep Mehta

Judgment Date

  • July 30, 2025

Caselaws and Citations

  • The judgment does not explicitly cite other case laws or precedents within the provided text. The focus is on the appreciation of evidence and application of statutory provisions.

Statutes/Laws Referred

  • Indian Penal Code, 1860
    • Section 302 (Punishment for murder)
  • Code of Criminal Procedure, 1973
    • Section 313 (Power to examine the accused)
  • Indian Evidence Act, 1872
    • Section 106 (Burden of proving fact especially within knowledge)