Court’s Decision
The Supreme Court set aside the conviction of the appellant under Section 302 IPC for the murder of the deceased and acquitted him. The Court found that the prosecution’s case rested entirely on circumstantial evidence, which failed to establish the appellant’s guilt beyond a reasonable doubt. It observed that:
- The chain of circumstances was not fully established, and gaps in the evidence created room for alternative possibilities.
- The prosecution failed to prove motive conclusively—the alleged wage dispute was minor and not a sufficient reason to commit murder.
- Last seen theory was weak—the appellant’s presence at the crime scene was based on the testimony of a single witness (PW-5), which was inconsistent.
- Weapon recovery was unreliable—the farsi (sharp weapon) was recovered 20-25 days after the incident, and there was no forensic evidence linking it to the murder.
- Witness contradictions created reasonable doubt about the appellant’s involvement.
Since the principles governing circumstantial evidence (established in Sharad Birdhichand Sarda v. State of Maharashtra, (1984) 4 SCC 116) were not satisfied, the Court acquitted the appellant, granting him the benefit of the doubt.
Facts of the Case
Background
The incident took place on March 28, 2002, in Village Ghotha Sakulpara, Bhanupratappur, District Kanker, Chhattisgarh. The prosecution alleged that the appellant had been working and staying with the deceased for two months before the murder.
On the morning of the incident, the following events allegedly took place:
- 7:00 AM – The appellant left the house for his native place on a cycle, carrying a bag.
- 9:00 AM – He returned, claiming his cycle had a puncture.
- He asked PW-5 (wife of the deceased) for money to repair it. She had none, so she offered him paddy to sell in the market. He refused.
- PW-5 went to the market alone, leaving the appellant and the deceased at home.
- 9:30 AM – When PW-5 returned, she saw the appellant running away holding a farsi and found her husband lying dead with his neck severed.
- PW-3 & PW-4 (neighbors) came after hearing her cries and confirmed seeing the deceased.
- PW-1 was informed and went to the police station to file an FIR at 11:15 AM.
Prosecution’s Theory
The prosecution’s entire case was based on circumstantial evidence, claiming that:
- The motive was a dispute over delayed wages.
- The appellant was the last person seen with the deceased before the murder.
- The weapon (farsi) was recovered based on his alleged disclosure.
- The injuries on the deceased matched the weapon’s characteristics.
Issues Before the Court
- Whether the prosecution established a complete chain of circumstantial evidence to prove the appellant’s guilt beyond a reasonable doubt?
- Whether the alleged motive was strong enough to support a conviction for murder?
- Whether the last seen theory was credible and sufficient to implicate the appellant?
- Whether the weapon recovery was properly linked to the crime?
- Whether witness inconsistencies weakened the prosecution’s case?
Petitioner’s (Appellant’s) Arguments
The appellant’s counsel challenged the conviction, arguing that the case was based on circumstantial evidence, which was insufficient to meet the legal standard of proof. The key arguments were:
1. No Direct Evidence
- There were no eyewitnesses to the crime.
- Even PW-5 (wife of the deceased) was not present at the time of the murder.
- PW-5’s statements were inconsistent—initially, she said she did not see the appellant, but later claimed she saw him running away with a weapon.
2. Weak “Last Seen” Theory
- The appellant’s return home was based only on PW-5’s statement, which was not corroborated.
- No independent evidence confirmed his presence at the time of the murder.
- The prosecution failed to verify the claim that the appellant’s cycle was punctured.
3. Unsubstantiated Motive
- The alleged wage dispute was not strong enough to justify a murder.
- No evidence showed that the appellant and deceased had serious conflicts.
4. Doubtful Recovery of the Weapon (Farsi)
- The farsi was found 20-25 days later.
- It was in an open area, not in the appellant’s possession.
- No forensic report confirmed the bloodstains on the weapon matched the deceased.
5. Contradictory Witness Statements
- PW-1 initially claimed he saw the appellant running, but later admitted he saw only a figure in the distance, without identifying him.
- PW-9, who allegedly produced the blood-stained clothes, turned hostile, making the evidence unreliable.
Respondent’s (Prosecution’s) Arguments
The prosecution argued that:
- The appellant had a clear motive—he was angry about his wages.
- PW-5 saw him fleeing from the crime scene with the weapon.
- The farsi was recovered based on the appellant’s statement.
- The injuries on the deceased were consistent with the farsi.
Analysis of the Law
The Supreme Court applied the five principles governing circumstantial evidence, as laid down in Sharad Birdhichand Sarda v. State of Maharashtra [(1984) 4 SCC 116]:
- The circumstances must be fully established.
- The facts must be consistent only with guilt.
- The evidence must be conclusive.
- The possibility of any other explanation must be ruled out.
- The evidence must form a complete chain leading only to the accused’s guilt.
The Court found that several gaps in the case violated these principles.
Precedent Analysis
The Court also relied on:
- Navaneethakrishnan v. State (2018) 16 SCC 161 – Benefit of doubt should be given when circumstantial evidence is weak.
- Digamber Vaishnav v. State of Chhattisgarh (2019) 4 SCC 522 – The absence of forensic evidence weakens circumstantial cases.
These precedents supported acquittal, as the prosecution’s case had too many uncertainties.
Court’s Reasoning
- No Clear Motive – The wage dispute was not serious enough to drive the appellant to murder.
- Weak Last Seen Evidence – No independent proof that the appellant returned home.
- Witness Contradictions – PW-5 and PW-1 changed their statements.
- Doubtful Weapon Recovery – No forensic report confirmed it was the murder weapon.
- Gaps in Circumstantial Evidence – The chain of events was not complete.
The Court ruled:
“The possibility of innocence is not excluded. The benefit of doubt must go in favor of the appellant.”
Conclusion
The Supreme Court acquitted the appellant, stating that the prosecution failed to prove guilt beyond a reasonable doubt. The conviction was overturned, and the appellant’s bail bonds were discharged.
Implications
- Higher Standards for Circumstantial Cases – Gaps in evidence can result in acquittals.
- Forensic Evidence is Critical – Lack of forensic proof weakens murder cases.
- Witness Credibility Matters – Contradictions reduce the strength of prosecution cases.
This judgment reinforces the principle that mere suspicion is not enough—proof beyond doubt is essential for conviction.
