Court’s Decision
The Supreme Court overturned the conviction and death sentence imposed by the Trial Court and affirmed by the High Court for offences of rape and murder of a four-year-old child. After an exhaustive re-examination of the evidence, the Court held that the prosecution failed to establish a complete and reliable chain of circumstantial evidence. The Court found glaring inconsistencies in witness testimonies, unreliability of the alleged extra-judicial confession, lack of independent corroboration, and a weak forensic report that did not link the accused to the crime. Holding that “suspicion, however grave, cannot substitute legal proof,” the Court acquitted the accused and directed his release.
Facts
The prosecution alleged that the accused had taken the four-year-old child from a wedding ceremony and later sexually assaulted and murdered her, disposing of the body in a sugarcane field. For six days, the family and villagers reportedly searched for the child. According to the prosecution, the accused confessed to the crime before family members, leading to recovery of the body and certain articles. The body was found in a highly decomposed state, partially eaten by animals. The post-mortem could not determine cause of death or confirm sexual assault. Several witnesses claimed to have last seen the accused with the child. The prosecution relied heavily on the alleged extra-judicial confession, last-seen theory, and the recovery of articles to secure conviction.
The Trial Court convicted the accused for murder and gang rape and imposed a death sentence. The High Court confirmed the conviction and sentence.
Issues
- Whether the circumstantial evidence presented by the prosecution formed a complete, consistent, and credible chain pointing unerringly towards the accused’s guilt.
- Whether the extra-judicial confession and recoveries were reliable and admissible.
- Whether the last-seen circumstance, combined with recovery, was sufficient to uphold a conviction for murder and rape.
- Whether the forensic report established any nexus between the accused and the alleged offences.
Petitioner’s Arguments
The petitioner argued that the conviction rested entirely on unreliable circumstantial evidence that failed to meet the legal standard required for a death sentence. It was submitted that the alleged extra-judicial confession was surrounded by contradictory statements regarding the place and manner in which it occurred. No independent witnesses were examined despite their admitted presence. The petitioner argued that the prosecution story was inherently improbable: the accused participated in the search for six days, no missing complaint was filed immediately, and villagers failed to notice foul smell from a decomposing body in a frequently accessed sugarcane field. It was argued that the last-seen theory alone could not sustain a conviction, especially when the forensic report failed to link the accused to the crime.
Respondent’s Arguments
The State contended that the cumulative circumstances—last-seen evidence, extra-judicial confession, recovery of the child’s body and articles on the accused’s pointing out, and the conduct of the accused—established guilt beyond reasonable doubt. The State argued that minor contradictions in witness testimonies were natural and immaterial. According to the prosecution, the recovery of the clothes and articles at the accused’s instance strongly corroborated the confession. The prosecution submitted that the brutality of the crime justified the imposition of the death penalty.
Analysis of the Law
The Court reiterated the long-standing principle that in cases based on circumstantial evidence, each link in the chain must be independently established and collectively capable of leading only to one conclusion: the guilt of the accused. The Court emphasized that suspicion cannot replace proof and that inconsistencies in crucial prosecution evidence must be viewed with caution. It reiterated that extra-judicial confessions are inherently weak, especially where credibility of witnesses and consistency of narrative are doubtful.
The Court stressed that the forensic report must furnish meaningful scientific corroboration. In this case, the report merely stated that the blood was human and semen was detected, without linking these findings to either the accused or the deceased.
Precedent Analysis
The judgment carefully examined several Supreme Court precedents:
1. Pritinder Singh alias Lovely v. State of Punjab (2023)
The Court relied on this case for the principle that circumstances must be fully established and should unerringly point to guilt. The Court applied the same rigor to the present case and found the chain incomplete.
2. Pradeep Kumar v. State of Haryana (2024)
Reaffirmed that where two views are possible, the one favorable to the accused must be adopted. This was invoked because several aspects of the case created reasonable doubt.
3. Kali Ram v. State of Himachal Pradesh (1973)
The iconic principle that “another man may possibly have committed the crime” was applied when considering the doubts surrounding witness conduct and unexplained delays.
4. Kalinga v. State of Karnataka (2024)
The judgment emphasized the weak nature of extra-judicial confessions and high threshold required for reliance. The current confession’s contradictions failed this standard.
5. Nikhil Chandra Mondal v. State of West Bengal (2023)
Reiterated that extra-judicial confession requires independent corroboration, which was missing here.
6. Krishnan v. State of Tamil Nadu (2014)
Confirmed that last-seen theory alone cannot result in conviction. The Court applied this directly, noting absence of corroboration.
7. Randeep Singh v. State of Haryana (2024)
Stressed that moral conviction cannot replace legal proof. The Court used this precedent to stress the importance of reasoned acquittal.
8. Sharad Birdhichand Sarda (1984)
The gold standard for circumstantial evidence. The Court held the present case failed the “five golden principles.”
Court’s Reasoning
The Court found significant flaws in the prosecution case:
- Contradictory accounts of the confession — witnesses gave three different locations, and one witness contradicted her own statement.
- No independent witnesses, despite their admitted presence at the alleged recovery.
- Unbelievable conduct — the accused joined the search for six days without raising suspicion.
- No missing complaint for six days, despite the child being four years old and last seen with the accused.
- Improbable recovery circumstances — no villager detected the corpse in an open, cultivated field despite foul smell.
- Forensic report had no evidentiary value — did not link the accused to the crime.
- Last-seen theory insufficient — particularly when other elements are doubtful.
- Possibility of involvement of other persons, including one witness whose conduct was questionable.
The Court held that the entire prosecution story appeared unnatural, inconsistent, and unreliable.
Conclusion
The Supreme Court set aside the conviction and death penalty, holding that the prosecution had failed to establish guilt beyond reasonable doubt. The Court reaffirmed that in a civilized legal system, even heinous crimes cannot justify departure from the fundamental requirement of proof. As the chain of evidence was incomplete and contaminated by doubt, the accused was ordered to be released unless required in another case.
Implications
This judgment reinforces the Supreme Court’s insistence on strict compliance with principles of circumstantial evidence. It sends a clear message that:
• Extra-judicial confessions must withstand rigorous scrutiny.
• Last-seen evidence cannot be decisive without corroboration.
• Forensic evidence must provide meaningful linkage.
• Courts must resist moral outrage when legal proof is deficient.
The judgment strengthens procedural fairness, particularly in capital punishment cases.
