A) ABSTRACT / HEADNOTE

The case of Anant Chintaman Lagu v. State of Bombay marks a watershed moment in Indian criminal jurisprudence, especially concerning convictions based solely on circumstantial evidence. The central issue revolved around the suspicious death of Laxmibai Karve, allegedly poisoned by Dr. Anant Lagu, a physician who had become deeply entrenched in her personal and financial affairs. Though the autopsy and chemical analysis failed to detect poison, the Supreme Court, by majority, upheld his conviction under Section 302 of the Indian Penal Code based on an intricate matrix of circumstantial evidence. The judgment delved into the admissibility and reliability of indirect proof when direct evidence is lacking and highlighted the significance of an accused’s conduct before and after the alleged crime. The Court stressed that corpus delicti can be established without detecting the poison if the circumstances unerringly point to guilt. Justice Hidayatullah and Justice S.K. Das upheld the conviction, while Justice Sarkar dissented, arguing that the prosecution had failed to conclusively establish that the death was unnatural. This judgment underscores the critical balance courts must maintain between safeguarding due process and ensuring that calculated crimes are not allowed to go unpunished due to procedural technicalities or lack of direct evidence.

Keywords: Murder by poisoning, Circumstantial evidence, Corpus delicti, Section 302 IPC, Diabetic coma, Medical jurisprudence

B) CASE DETAILS

i) Judgement Cause Title
Anant Chintaman Lagu v. The State of Bombay

ii) Case Number
Criminal Appeal No. 73 of 1959

iii) Judgement Date
14 December 1959

iv) Court
Supreme Court of India

v) Quorum
S.K. Das, A.K. Sarkar, and M. Hidayatullah, JJ.

vi) Author
Justice M. Hidayatullah delivered the majority judgment; Justice Sarkar dissented

vii) Citation
1960 (2) SCR 460; AIR 1960 SC 500

viii) Legal Provisions Involved

• Section 302, Indian Penal Code, 1860 – Murder

• Indian Evidence Act, 1872 – Circumstantial evidence, Section 106 (Burden of proving fact especially within knowledge)

• Code of Criminal Procedure, 1898 (as applicable at the time)

ix) Judgments Overruled by the Case
None explicitly overruled

x) Case is Related to Which Law Subjects
Criminal Law, Medical Jurisprudence, Evidence Law

C) INTRODUCTION AND BACKGROUND OF JUDGEMENT

The appellant, Dr. Anant Lagu, a medical practitioner, was accused of murdering his patient Laxmibai Karve, a wealthy widow, with the intent of misappropriating her substantial wealth. The case became complicated due to the absence of direct proof of poisoning. No trace of poison was found in the autopsy or chemical analysis. Nonetheless, a comprehensive web of circumstances, including forged documents, the accused’s conduct, disappearance of the deceased’s wealth, and misrepresentations after her death, became the fulcrum of the prosecution’s case. The Supreme Court’s role was to examine whether these circumstances were sufficient to infer murder and uphold the conviction and death sentence imposed by the Bombay High Court and the Sessions Judge of Poona.

D) FACTS OF THE CASE

Laxmibai Karve, also known as Mai Karve, was the widow of a prosperous businessman and lived independently in Poona. Following the death of her son, she inherited substantial movable and immovable assets including shares, jewelry, and cash deposits. Dr. Anant Lagu, who had previously treated her husband and son, became her personal physician and confidant. He gradually took control over her financial and personal life. On the night of 12 November 1956, Lagu accompanied Laxmibai to Bombay purportedly for a medical consultation. By early morning of 13 November, he admitted her unconscious to the G.T. Hospital under a false name and medical history. She died within hours. Lagu made no effort to inform family or claim the body, which was eventually marked unclaimed. In the following months, he forged documents, impersonated communications allegedly from Laxmibai indicating she had gone on a pilgrimage and married, and misappropriated her wealth. He was arrested in March 1958 after suspicions arose. The prosecution built a case relying entirely on circumstantial evidence.

E) LEGAL ISSUES RAISED

i) Whether the absence of poison in the autopsy negated the possibility of death by poisoning?
ii) Whether circumstantial evidence alone was sufficient to uphold a conviction under Section 302 IPC?
iii) Whether the conduct of the accused before and after the death of the deceased pointed conclusively to his guilt?
iv) Whether medical evidence aligned with homicidal death by poison despite no traces of poison found?

F) PETITIONER / APPELLANT’S ARGUMENTS

i) The counsels for Petitioner / Appellant submitted that
There was no scientific proof of death by poisoning. The post-mortem report and chemical analysis did not detect any poisonous substance. They argued that the medical evidence failed to indicate death was caused by unnatural means. The defense claimed that Laxmibai died of natural causes, particularly diabetic coma or some other ailment, and the appellant’s conduct might be unethical or greedy but did not substantiate a charge of murder. The appellant’s subsequent financial actions were attempted justifications of charity. They further submitted that the conviction rested on speculative inferences rather than proven facts, making it unsafe for a death sentence.

G) RESPONDENT’S ARGUMENTS

i) The counsels for Respondent submitted that
The cumulative circumstances were incompatible with innocence. Lagu’s conduct before, during, and after the death exhibited deliberate planning, fraudulent intentions, and a clear attempt to suppress the death’s occurrence. He gave a false name, misled hospital staff, and took no steps to inform relatives. He actively misappropriated property and fabricated letters to create a false narrative that Laxmibai was alive. The absence of poison did not negate poisoning since some poisons may not be traceable, as held in Regina v. Onufrejczyk [1955] 1 Q.B. 388. They contended that the “chain of circumstances” established corpus delicti and pointed unerringly towards guilt.

H) RELATED LEGAL PROVISIONS

i) Section 302, Indian Penal Code, 1860
https://indiankanoon.org/doc/311575/
ii) Section 106, Indian Evidence Act, 1872
https://indiankanoon.org/doc/1733364/
iii) Principle of Corpus Delicti in murder cases
iv) Medical Jurisprudence concerning poisoning
v) Presumption of guilt from unexplained possession of deceased’s property

I) JUDGEMENT

a. RATIO DECIDENDI

i) Justice Hidayatullah, writing for the majority, held that circumstantial evidence can validly establish corpus delicti. Even in the absence of poison detected in the deceased’s body, if the cumulative circumstances rule out natural death and the conduct of the accused indicates homicide, the conviction can stand. The medical evidence and conduct post-death (false identity, concealment, forging documents, and appropriation of property) pointed conclusively towards a murder by administering an undetectable poison.

Reference was made to the English decisions like The King v. Horry [1952] NZLR 111 and Mary Ann Nash’s Case (1911) 6 Cr App R 225 which support conviction on circumstantial evidence when poison is not traceable but other facts are conclusive.

b. OBITER DICTA 

i) The Court warned that mere failure to detect poison should not paralyze judicial inquiry. Scientific limitations cannot be used as a refuge by cunning criminals. Medical evidence, when inconclusive, can be weighed with surrounding circumstances to infer the true cause of death.

c. GUIDELINES

• In cases of suspected poisoning, failure to detect poison is not fatal if circumstantial evidence is strong.

• Courts must examine the conduct of the accused in entirety, especially when they are the only persons with the deceased at critical times.

• Fabrication of facts post-death (e.g., fake letters, identity concealment) serves as crucial incriminatory conduct.

• The doctrine of last-seen together and falsus in uno applies with enhanced significance in cases lacking direct proof.

• The burden under Section 106 of the Indian Evidence Act shifts to the accused to explain facts exclusively within their knowledge.

J) CONCLUSION & COMMENTS

The decision in Anant Chintaman Lagu v. State of Bombay is a classic example of Indian courts’ pragmatic approach in handling cases based on circumstantial evidence. The case underscored the judiciary’s capacity to ensure that sophisticated offenders exploiting the limitations of forensic science are not exonerated merely due to absence of direct proof. The judgment fortified the principle that circumstantial evidence, if comprehensive and logically interconnected, can validly replace direct testimony. Justice Hidayatullah’s analytical rigor ensured the jurisprudence around murder by untraceable poisoning was firmly grounded. Despite the dissent from Justice Sarkar, the verdict remains a landmark in interpreting Section 302 IPC in poisoning cases with no poison detected.

K) REFERENCES

a. Important Cases Referred

[1] Regina v. Onufrejczyk, [1955] 1 Q.B. 388
[2] The King v. Horry, [1952] NZLR 111
[3] Mary Ann Nash’s Case, (1911) 6 Cr. App. R. 225
[4] Donald’s Case, (1817) 2 C. & K. 308n
[5] Anant Chintaman Lagu v. State of Bombay, 1960 (2) SCR 460; AIR 1960 SC 500

b. Important Statutes Referred

[6] Indian Penal Code, 1860, Section 302
[7] Indian Evidence Act, 1872, Section 106
[8] Code of Criminal Procedure, 1898 (applicable provisions)
[9] Indian Medical Jurisprudence (Textbooks and practice)