Author: Heemani Amarsingh Rajput,
BVDU New Law College ,Pune
To The Point
The statistics of Indian crimes and judicial busy refute the stereotype that the homicide of the intimate couple is only “husband-husband’s wife.”
• The National Office of Crime Registries (NCRB) registered 28,522 murders in 2022; Among the declared reasons, “love affairs” (1,401 murders) and “illicit relationships” (1,420) jointly occupy the third place after “disputes” and “personal revenge.”
• The 2023 crime report in India also classifies love affairs as the third largest murder driver throughout the country.
• Recent judgments show wives that conspire with lovers, husbands that unleash lethal violence over jealousy or dowry, and the courts that fight with the IPC neutral gender application 302 (murder), 304-B (Dowry-Death), 498-A (bloody) and 120-b (conspiracy).
The phenomenon, therefore, demands a lens that is gender agnostic but sensitive to context.
Use of Legal Jargon
•The Mens rea – guilty mind that differentiates intentional murder (§l302) from a sudden fight (304 Part II).
•Causus mortis –The immediate biomedical cause of death; crucial in strangulation or poisoning autopsies.
•Presumption under the Evidence Act – once the prosecution proves that a woman’s unnatural death within seven years of marriage preceded by dowry-linked cruelty, the court shall presume dowry-death.
•Abetment (IPC 107) – instigation or aid; often tagged to “in-laws or lovers” who help plan or cover up the crime.
•Doctrine of the Sudden Provocation – This may reduce murder to culpable homicide if the act follows an immediate, grave provocation without pre-meditation.
The Proof
1. Data snapshot
• The reasons linked to love represented 2,821 of the 28,522 murders of India in 2022, which underlines a trigger of neutral gender: romantic conflict.
• While NCRB still classifies the sex of victims asymmetrically (crimes against women against generic murder), independent studies notice 21,500 male suicides linked to marriage discord in 2022, hinting at not registered male victimization.
2. Recent cases of woman against man (2024–25)
Bareilly, U.P. -Aarci, 25, and her 17 -year -old lover stabbed and strangled her husband; Life imprisonment (January 9, 2025).
• Naghedi, Gujarat – wife and lover beaten and then lit the husband (August 18, 2024).
3. Recent cases of men against female (2024–25)
• Mumbai, Maharashtra-Wasim Shaikh strangled the 24-year-old wife after he rejected money for alcohol (June 24, 2025).
• AGRA, U.P. -Manoj Goswami sentenced to life imprisonment for strangulation motivated by the dowry and cover -up attempt (May 30, 2025).
These narratives discredit the notion of a pattern of intimate couple violence in a single direction.
Abstract
This article interrogates marital homicide in India through a doctrinal and empirical analysis balanced by gender. Trusting the NCRB data sets and convictions of the 2024-25 trial court, explore how the Indian Criminal Law navigates the murders of wives and husbands. The jurisprudence of the Supreme Court on presumptions and capital sentences of the dowry death illustrates an evolutionary approach that drives deterrence with the safeguards of due process. Ultimately, the reduction of the lethal violence of the intimate couple requires data reform (reasons of homicides disaggregated by sex), legislation of neutral gender protection, early height systems at the level of family and police court, and robust forensic infrastructure.
Case Laws
1. Sangli – Radhika Lokhande
•Date: June 12, 2025
•Victim: Anil Lokhande, 53, second marriage
•Perpetrator: Radhika Lokhande, 27, his new wife
•What happened: Just 15 days after their marriage, a midnight quarrel over consummation escalated. Radhika allegedly attacked Anil with an axe, killing him in his sleep.
2. Yavatmal – Nidhi Deshmukh
•Date: May 2025 (poisoning mid‑May; body found May 15)
•Victim: Shantanu Arvind Deshmukh, 32, school teacher
•Perpetrator: Nidhi Deshmukh, school principal (wife)
•What happened: Nidhi allegedly poisoned her husband on May 13, then enlisted three minor students to help dispose of and burn the body in Chousala forest. The body surfaced May 15.
3. Bengaluru (Mar 22, 2025):
Yashaswini (21) and her mother Hema Bai allegedly drugged and slit husband Loknath Singh’s throat in a car, reportedly due to marital distrust.
4. Jaipur, Rajasthan (Mar 15, 2025):
Gopali Devi and her lover killed husband Dhannalal Saini with an iron rod and rope, burnt the body, triggered by his confrontation about her affair.
5. Meghalaya Honeymoon Case (May 23, 2025): Sonam Raghuvanshi allegedly orchestrated the murder of husband Raja by hiring contract killers during their honeymoon. Raja’s body was found June 2.
FAQs
Q1. Is Section 498-A IPC available to male victims?
No. Section 498-A protects a woman against cruelty by husband or relatives. Male victims must rely on general IPC provisions (e.g., hurt, criminal intimidation) and the soon-to-be-notified Bharatiya Nyaya Sanhita provisions.
Q2. How does a court decide between §304-B (dowry death) and §302 (murder)?
Where homicidal violence is proved (strangulation, gunshot, poisoning), courts invoke §302; §304-B applies primarily to “unnatural deaths” (burns, hanging) within seven years of marriage linked to dowry harassment.
Q3. Can extramarital affair alone justify a lesser sentence?
No. Jealousy or infidelity is not a statutory defence; it may, at best, be a mitigating factor during sentencing if the act was sudden and without pre-meditation.
Q4. Why are conviction rates low in domestic killings?
Factors include hostile witnesses from the same family, pressure to settle, inadequate forensic infrastructure, and delayed evidence collection.
Q5. Are live-in partners covered?
Yes. Courts treat long-term live-in relationships as “relationships in the nature of marriage,” bringing them within the ambit of IPC homicide provisions; the Shraddha Walkar case is the archetype.
