Stepdaughter Accused of Strangling Stepmother and Minor Stepbrother; Supreme Court Upholds Acquittal, Says DNA Match and Suspicious Circumstances Cannot Replace Complete Chain of Proof
Trial Court Convicts Woman of Double Murder on Last-Seen, DNA and Key-Recovery Evidence; Supreme Court Finds Investigation Lapses and Upholds High Court Acquittal
Facts
The case arose from the deaths of Mithilesh Kumari and her minor son, Bhupinder Singh, at their residence in Diur, Himachal Pradesh. On 7 September 2011, Mithilesh’s father, Bhagi Ram (PW-1), informed the police that his daughter had been missing for six to seven days, her house was locked, and a foul smell was emanating from it. When the police entered the house after allegedly breaking the lock, they found the bodies of Mithilesh and her minor son. Post-mortem examination established that both deaths were homicidal and caused by strangulation.
The accused, Anchla @ Chanchla, was the daughter of Amar Singh from his first marriage. After the death of his first wife, Amar Singh had married Mithilesh, and Bhupinder was born from that marriage. The prosecution alleged that Anchla murdered her stepmother and stepbrother because her father had purportedly bequeathed his property to Bhupinder.
The prosecution principally relied upon a chain of circumstantial evidence. PW-1 claimed that on the evening of 31 August 2011, he had seen Anchla at Mithilesh’s house and had been told that Anchla would stay there overnight. The next morning the house was found locked.
A taxi driver, PW-4, claimed that he had driven Anchla from Chamba to Diur on the evening of 31 August and taken her back to Chamba late that night. He also claimed that Anchla had a bleeding injury on her hand. A hotel worker, PW-18, was relied upon to establish that Anchla stayed at a hotel in Chamba that night.
The prosecution further claimed that, following Anchla’s disclosure statement, the deceased’s mobile phone without its SIM card and a bunch of keys were recovered. An OPD slip showed that Anchla had received sutures for an injury on 1 September 2011. Most importantly, forensic analysis showed that the DNA profile generated from Anchla’s blood sample matched dried blood collected from the deceased’s house. The recovered keys were also said to operate the lock allegedly broken at the deceased’s house.
Anchla denied the incriminating circumstances. She admitted that the deceased were her stepmother and stepbrother and that she had suffered a hand injury, but explained that her hand had been crushed in a car door while travelling to Mani Mahesh. She also examined a defence witness concerning that journey.
Trial Court Conviction and High Court Acquittal
The Sessions Court convicted Anchla under Section 302 IPC. It relied upon the homicidal deaths, the alleged last-seen circumstance, her late-night journey from Diur to Chamba, her thumb injury, recovery of the deceased’s mobile and keys, and the DNA match between her blood and the blood recovered from the deceased’s house. It considered these circumstances sufficient to form a complete chain pointing towards Anchla’s guilt.
The Himachal Pradesh High Court reversed the conviction. Among other deficiencies, it found that PW-1’s claim of having seen Anchla talking to Bhupinder was absent from his earlier Section 161 CrPC statement; the alleged property motive had not been proved; the taxi driver’s evidence was doubtful; there was no hotel record corroborating PW-18; and there were discrepancies concerning the lock allegedly broken by the police.
The State of Himachal Pradesh consequently approached the Supreme Court challenging the acquittal.
Issue
The principal issue before the Supreme Court was whether the High Court’s acquittal represented a reasonably possible view of the evidence or whether it was perverse and required interference.
Closely connected was the question whether the circumstances relied upon by the prosecution—last seen, the accused’s movements, her injury, DNA evidence, recovery of keys and the deceased’s mobile, and alleged motive—had individually been proved beyond reasonable doubt and collectively formed an unbroken chain excluding every reasonable hypothesis consistent with innocence.
State’s Arguments
The State argued that the High Court had discarded crucial prosecution evidence on conjectures and surmises.
It submitted that the DNA evidence was particularly significant. Anchla’s blood was found at the crime scene, and evidence showed that she had suffered a bleeding injury on the relevant night. According to the State, these circumstances, particularly in the absence of a satisfactory explanation, strongly connected her with the murders.
The State also contended that there was no justification for rejecting PW-1, PW-4 and PW-18. The delay by PW-1 in reporting the disappearance was explained because he initially had no reason to suspect foul play.
The recovery of keys capable of operating the lock of the deceased’s house was also said to constitute an important incriminating circumstance. The State therefore argued that the High Court’s acquittal was perverse and that the Trial Court’s conviction ought to be restored.
Respondent-Accused’s Arguments
Anchla argued that the prosecution case rested entirely upon circumstantial evidence and that several vital links in the alleged chain were missing.
She submitted that “last seen” evidence is inherently weak unless the interval between the accused allegedly being with the deceased and the death is sufficiently narrow to exclude intervention by another person. Here, she was allegedly seen on 31 August 2011, whereas the bodies were discovered only on 7 September 2011.
The credibility of the taxi driver and hotel employee was also challenged. There was no documentary record establishing her hotel stay, and the circumstances surrounding those witnesses were alleged to be artificial.
As regards the DNA evidence, the defence argued that Anchla had regularly visited the deceased’s house, meaning that the mere presence of her blood there did not conclusively establish that she committed the murders.
The alleged recovery of the keys was also disputed because the prosecution had not reliably established that the lock tested by the forensic laboratory was the very lock that had secured the deceased’s house.
Finally, the alleged property motive was challenged because there was no evidence proving the supposed bequest in favour of Bhupinder.
Supreme Court on Appeals Against Acquittal
The Supreme Court reiterated that an appellate court possesses the power to review evidence even after an acquittal. However, an acquittal strengthens the presumption of innocence.
Where two reasonable views of the evidence are possible—one pointing towards guilt and another towards innocence—the view favourable to the accused ordinarily has to prevail. Interference is warranted where the acquittal is perverse, palpably erroneous, ignores compelling evidence or results in a miscarriage of justice.
The Court nevertheless clarified that where convincing evidence has been unjustifiably discarded, the appellate court can reappreciate the evidence and interfere.
Circumstantial Evidence Must Form a Complete Chain
Since there was no direct evidence of the murders, the prosecution was required to satisfy the established principles governing circumstantial evidence.
Every incriminating circumstance had to be fully proved; the proved circumstances had to be consistent only with guilt; they had to be conclusive in nature; and the entire chain had to exclude every reasonable hypothesis consistent with innocence.
The Supreme Court found that the prosecution case failed this test.
Last-Seen Evidence Was Unreliable
The Court regarded the alleged last-seen circumstance as central to the prosecution case.
PW-1 claimed at trial that he had seen Anchla talking to Bhupinder at the deceased’s house. However, this assertion did not appear in his earlier Section 161 CrPC statement. The Court treated it as a material improvement.
It therefore held that it would be unsafe to conclude solely from PW-1’s evidence that Anchla was with the deceased on the evening of 31 August 2011.
There was another important difficulty: the autopsy was conducted on 8 September and estimated that the deaths had occurred five to seven days earlier. Consequently, the possibility that the deaths occurred after the night of 31 August/1 September could not be excluded.
Taxi Driver and Hotel Witness Did Not Inspire Confidence
The Supreme Court undertook a detailed examination of PW-4, the taxi driver, and PW-18, the hotel employee.
The Court found it significant that the Investigating Officer could not explain what prompted him to record their statements or even clearly disclose when those statements had been recorded.
This led the Court to make an important observation on criminal investigation: the function of an investigating officer is to collect evidence, not create it. Where there is no apparent reason why a particular witness would possess or volunteer relevant information, the prosecution must satisfactorily explain how that witness came into the investigation. Failure to do so may legitimately cast doubt upon whether the witness was subsequently introduced to complete the prosecution story.
The absence of the hotel’s guest record further undermined PW-18’s evidence. Ultimately, the Court found PW-4 and PW-18 insufficiently trustworthy to corroborate the alleged last-seen circumstance.
Failure to Obtain Mobile Tower Locations Was a Serious Investigational Lapse
The investigating agency had obtained call detail records relating to the relevant mobile phones but failed to obtain corresponding tower-location data.
The Supreme Court regarded this as a serious lapse because the tower locations could have objectively established whether Anchla’s mobile and Mithilesh’s mobile were in proximity at the relevant time.
They could also have shown whether Mithilesh’s mobile remained active after 31 August and, if so, where it was located. The deceased’s CDR itself was not even exhibited.
The Court considered this evidence particularly significant because it had the potential either to corroborate or demolish the prosecution’s central theory.
Recovery of Lock, Keys and Mobile Was Not Reliably Established
The prosecution relied heavily upon the alleged recovery of a bunch of keys from Anchla and the forensic opinion that some of those keys operated the lock seized from the deceased’s house.
The Supreme Court held that this circumstance could become incriminating only if the prosecution first established beyond reasonable doubt that the lock produced and examined was the same lock that had actually secured the room containing the bodies.
The evidence did not satisfactorily establish that foundational fact. The prosecution therefore could not convert the forensic compatibility between the keys and the lock into a conclusive link connecting Anchla with the murders.
DNA Match Was Not Conclusive of Murder
The Supreme Court did not disregard the DNA match. Instead, it considered its evidentiary value in the context of the entire case.
Anchla was admittedly a regular visitor to the deceased’s house. Therefore, the presence of her blood inside the premises was not, standing alone, conclusive proof that she committed the murders.
Significantly, her blood was not detected on the clothes of either deceased or on the cloth allegedly used for strangulation.
Thus, while the DNA evidence established the presence of Anchla’s blood at the house, it could not establish the crucial further inference that the blood was deposited during the commission of the murders.
Alleged Property Motive Was Not Proved
The prosecution alleged that Anchla killed her stepmother and stepbrother because her father had bequeathed his property to Bhupinder.
The Supreme Court found no evidence proving such a bequest.
It further noticed that Anchla was not the only daughter from her father’s first marriage. There were five daughters. Therefore, even if Bhupinder were removed, Anchla alone would not necessarily obtain the alleged property benefit.
The prosecution consequently failed to establish a strong motive for the double murder.
Court’s Reasoning
The Supreme Court ultimately found multiple broken links in the prosecution chain.
The precise time of death was uncertain. Anchla’s presence at the deceased’s house was not established beyond reasonable doubt. The principal last-seen witness had materially improved his version. The taxi driver and hotel witness were unreliable. The identity of the lock was doubtful. Recovery of the keys and mobile did not inspire confidence. Critical tower-location evidence was not collected. The alleged motive was unproved.
Even the DNA evidence, although scientifically establishing a match, did not answer when or in what circumstances Anchla’s blood came to be present in a house she admittedly visited regularly.
The prosecution was therefore unable to transform a collection of suspicious circumstances into a legally complete chain of circumstantial evidence.
Conclusion
The Supreme Court held that although Mithilesh Kumari and Bhupinder Singh had unquestionably suffered homicidal deaths, the prosecution failed to establish beyond reasonable doubt that Anchla was their murderer.
The incriminating circumstances were neither individually established with the required certainty nor collectively sufficient to exclude every hypothesis consistent with innocence.
The Supreme Court consequently found no reason to interfere with the Himachal Pradesh High Court’s judgment acquitting Anchla and dismissed the State’s appeal.
Case Details
Case: The State of Himachal Pradesh v. Anchla @ Chanchla
Citation: 2026 INSC 1074
Court: Supreme Court of India
Proceeding: Criminal Appeal No. 166 of 2019
Bench: Justice Manoj Misra and Justice Vijay Bishnoi
Judgment authored by: Justice Manoj Misra
Date: 1 October 2026
Key provision: Section 302, Indian Penal Code, 1860
Nature of case: Double murder prosecution based entirely on circumstantial evidence
Result: State’s appeal dismissed; High Court acquittal upheld.
