Pundalik vs State Of Maharashtra

The Supreme Court upheld the conviction of the appellant under Section 302 IPC for the murder of his wife, Rukhmabai, despite the sole eye-witness, his daughter, not supporting the prosecution. The Court found that the circumstantial evidence was sufficient to establish guilt, rejecting the appellant's argument that the incident occurred in the heat of passion, which would invoke Exception 4 to Section 300 IPC. The Court partly allowed the appeal, indicating that the case may fall under Section 302 Part II instead of Part I, thus modifying the conviction.