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1. Court’s Decision
The Supreme Court allowed the appeal and acquitted the appellant, overturning the convictions by the Sessions Court and High Court. The Court held that the prosecution failed to establish a complete and unbroken chain of circumstantial evidence linking the accused to the crime. The appellant was ordered to be released unless required in any other case.
2. Facts of the Case
- The case involved the alleged kidnapping and murder of a minor girl.
- A First Information Report (FIR) was lodged by the victim’s father four days after she went missing, alleging that the appellant and a co-accused had kidnapped her with the intention to marry her.
- The victim’s dead body was later found near a railway track.
- The prosecution charged the appellant under Sections 366(A) (kidnapping), 302 (murder), 201 (causing disappearance of evidence), and 34 (common intention) of the Indian Penal Code (IPC).
- The Sessions Court convicted the appellant, sentencing him to rigorous imprisonment for five years for kidnapping and life imprisonment for murder.
- The High Court upheld the conviction for murder but acquitted him of the kidnapping charge.
- The case primarily relied on circumstantial evidence, including the doctrine of last seen together and alleged extra-judicial confessions.
3. Issues Raised
- Did the circumstantial evidence establish guilt beyond a reasonable doubt?
- Was the extra-judicial confession admissible in evidence?
- Did the doctrine of ‘last seen together’ justify conviction?
- Did the alleged discovery of the victim’s body at the appellant’s instance satisfy Section 27 of the Indian Evidence Act?
4. Petitioner’s (Appellant’s) Arguments
- Circumstantial evidence was incomplete – The prosecution failed to prove an unbroken chain of events that pointed solely to the guilt of the accused.
- The extra-judicial confession was inadmissible – The confession was made in police custody, violating Section 25 of the Indian Evidence Act.
- The ‘last seen together’ theory was unreliable – There was a significant five-day gap between the victim last being seen with the appellant and the recovery of her body.
- The discovery of the body was unreliable – Witness testimonies regarding the discovery of the body contained contradictions.
- Lack of motive – The appellant and the victim were in a romantic relationship, and the appellant’s family had promised to arrange their marriage, reducing the likelihood of a motive to kill her.
- Investigative failures – The blood-stained vest was not sent for forensic testing, and key witnesses (such as the appellant’s mother and brother-in-law) were not examined.
5. Respondent’s (State’s) Arguments
- The conviction was justified based on circumstantial evidence.
- The appellant failed to explain his presence with the victim before her death, strengthening the case against him.
- The extra-judicial confession led to the discovery of the body, making it admissible under Section 27 of the Indian Evidence Act.
- The absence of motive did not absolve the appellant of guilt, as circumstantial evidence was sufficient.
- The High Court correctly appreciated the evidence and upheld the conviction.
6. Analysis of the Law
The Court analyzed various legal principles:
(a) Circumstantial Evidence
- Circumstantial evidence must form a complete chain of events leading only to the guilt of the accused.
- If any link in the chain is missing, the accused is entitled to acquittal.
(b) Extra-Judicial Confession
- Confessions made in police custody are inadmissible under Section 25 of the Indian Evidence Act.
- The High Court itself rejected the extra-judicial confession, undermining a crucial part of the prosecution’s case.
(c) Doctrine of ‘Last Seen Together’
- The time gap between the accused last being seen with the victim and the discovery of the body was too long (five days).
- The Supreme Court held that such a long time gap made the theory unreliable.
(d) Discovery Under Section 27 of the Evidence Act
- The discovery of the body allegedly based on the appellant’s confession was found to be unreliable due to contradictions in witness statements.
- Inconsistent testimonies weakened the claim that the appellant led police to the body.
7. Precedent Analysis
The Supreme Court referred to several landmark cases:
- Ramu Appa Mahapatar v. State of Maharashtra (2025)
- Circumstantial evidence must prove guilt beyond reasonable doubt.
- State of Goa v. Sanjay Thakran (2007)
- The ‘last seen together’ doctrine applies only when the time gap is minimal.
- Kanhaiya Lal v. State of Rajasthan (2014)
- Last seen together alone is not enough to convict an accused.
- Pulukuri Kottaya v. King-Emperor (1947)
- Section 27 of the Evidence Act applies only to information leading to new discovery, not confirming prior police suspicion.
- Anwar Ali v. State of Himachal Pradesh (2020)
- Absence of motive is significant in cases based on circumstantial evidence.
8. Court’s Reasoning
- The prosecution’s case had inconsistencies, including contradictions in witness statements and lack of forensic evidence.
- The High Court’s rejection of the extra-judicial confession weakened the prosecution’s case.
- The five-day gap in the ‘last seen together’ theory weakened its probative value.
- Failure to send the blood-stained vest for forensic testing was a critical lapse.
- Failure to examine key witnesses (appellant’s mother and brother-in-law) raised doubts.
- Lack of motive further weakened the circumstantial evidence.
9. Conclusion
- The Supreme Court held that the prosecution failed to establish guilt beyond a reasonable doubt.
- The circumstantial evidence was incomplete, and the chain of events was broken.
- The appellant was acquitted and ordered to be released.
10. Implications of the Judgment
- Stricter Standards for Circumstantial Evidence
- Courts will require a complete and unbroken chain of evidence before convicting an accused.
- Limitations on the ‘Last Seen Together’ Doctrine
- The time gap between last seen and discovery must be minimal.
- Reaffirmation of Confession Rules
- Confessions made in police custody remain inadmissible unless under Section 27.
- Need for Proper Investigation
- Failure to send forensic evidence for testing can weaken a case.
- Key witnesses must be examined to strengthen the prosecution’s case.
- Prevention of Wrongful Convictions
- The ruling safeguards against wrongful convictions based on weak circumstantial evidence.