Supreme Court acquits accused in murder case based on circumstantial evidence: Satish Nirankari vs. State of Rajasthan (2017)

Date of the Judgment: 09 June 2017

Citation: 2017 INSC 545

Judges: A.K. Sikri, J., Ashok Bhushan, J.

Can a conviction for murder stand when the case is based entirely on circumstantial evidence and there’s a possibility of suicide? The Supreme Court of India recently addressed this question in a case where a young woman was found dead, and the accused, her partner, was charged with murder. The core issue was whether the prosecution had sufficiently proven that the death was a homicide and not a suicide. The bench, comprising Justices A.K. Sikri and Ashok Bhushan, delivered the judgment.

Case Background

On November 1, 1995, Pooja, daughter of Pramod Bhatnagar, went missing after leaving her home at 5:30 PM to attend her MBA classes. When she didn’t return by 9:00 PM, her family became worried. Around 10:00 PM, they were informed by Ashok that Pooja was admitted to SMS Hospital, Jaipur. Upon reaching the hospital, they discovered that Pooja had already died. Her father alleged that the appellant, Satish Nirankari, had murdered her by strangulation.

The next morning, a written report was lodged at the Gandhi Nagar Police Station, Jaipur. The police registered a case, conducted an autopsy on Pooja’s body, recorded witness statements, and arrested Satish. The case was brought before the Special Judge, Jaipur, who framed charges against Satish under Section 302 (murder) and Section 309 (attempt to commit suicide) of the Indian Penal Code (IPC). Satish denied the charges, claiming that Pooja had committed suicide and that he had also attempted suicide.

Timeline

Course of Proceedings

The Special Judge, after analyzing the prosecution’s evidence, concluded that the prosecution had proven the charges against Satish beyond a reasonable doubt. The trial court held that Pooja did not commit suicide but was murdered by Satish. Satish was sentenced to life imprisonment for murder under Section 302 of the IPC and three months of simple imprisonment for attempting suicide under Section 309 of the IPC.

Satish appealed the judgment to the High Court of Judicature for Rajasthan under Section 374 of the Code of Criminal Procedure (Cr.PC). The High Court dismissed the appeal on February 19, 2007, upholding the trial court’s decision. Aggrieved by this, Satish appealed to the Supreme Court.

Legal Framework

The case primarily revolves around the interpretation and application of the following legal provisions:

• Section 302 of the Indian Penal Code (IPC): This section defines the punishment for murder. It states, “Whoever commits murder shall be punished with death, or imprisonment for life, and shall also be liable to fine.”
• Section 309 of the Indian Penal Code (IPC): This section deals with the attempt to commit suicide. It states, “Whoever attempts to commit suicide shall be punished with simple imprisonment for a term which may extend to one year or with fine, or with both.”
• Section 374 of the Code of Criminal Procedure (Cr.PC): This section provides for appeals from convictions.
• Section 313 of the Code of Criminal Procedure (Cr.PC): This section deals with the power of the court to examine the accused.
• Section 106 of the Indian Evidence Act: This section deals with the burden of proving facts especially within knowledge.
• Section 101 of the Indian Evidence Act: This section deals with the burden of proof.

Arguments

Appellant’s Arguments:

• The appellant’s counsel, Mr. Huzefa Ahmadi, argued that the circumstantial evidence pointed towards suicide, not murder. He emphasized the love affair between Satish and Pooja, the opposition from Pooja’s parents, and the fact that Pooja was allegedly beaten by her parents on the day of the incident.
• He argued that Pooja, upset and determined to marry Satish, had purchased makeup items, bangles, and garlands, and they got married before a photo of God. However, she became paranoid about her family’s reaction and decided to commit suicide. Satish, unable to live without her, also decided to end his life.
• Mr. Ahmadi highlighted that Satish, after seeing Pooja’s deteriorating condition, sought help from a neighbor, Vinod Kumar Gupta (PW-4), and even threw stones at his house to gain his attention. This conduct, he argued, showed that Satish did not kill Pooja.
• He pointed out that the prosecution failed to establish a motive for murder. He questioned why Pooja would be wearing makeup and sindoor if she was going to be murdered. He also argued that the prosecution did not examine Ashok, who informed Pooja’s father about her hospitalization.
• The defense argued that the possibility of suicide could not be ruled out, and that the suicide note (Ex. P-3) was indeed written by Pooja. The courts below had wrongly ignored the investigating officer’s statement that witnesses had stated the suicide note was in Pooja’s handwriting.
• Mr. Ahmadi referred to the deposition of Vidya Bhushan (PW-1), who supported the appellant’s version that Pooja and Satish were in love, and that Pooja’s parents were opposing their marriage. He also cited the testimony of Pramod Bhatnagar (PW-12), Pooja’s father, who admitted that inter-caste marriages were not accepted in their family.

State’s Arguments:

• The State’s counsel argued that the evidence conclusively proved that Satish had murdered Pooja. They relied on the depositions of Manju Bhatnagar (PW-8), Pramod Bhatnagar (PW-12), and Pramila Bhatnagar (PW-9), who stated that the suicide note (Ex. P-3) was not written by Pooja. They also pointed out that Pooja was not in the habit of writing in Hindi.
• The State Counsel highlighted that Pooja was ambitious and planning to apply for post-graduate studies, which made it unlikely that she would commit suicide. They also relied on the post-mortem report, which stated that the cause of death was asphyxia due to pressure on the neck with a ligature.
• The State argued that the story projected by Satish, that Pooja had hanged herself after consuming poison, was improbable. They also questioned how Pooja, a stranger to the house, could have found copper sulphate there.

Issues Framed by the Supreme Court

The Supreme Court framed the following issue for consideration:

1. Whether the prosecution has proved beyond reasonable doubt that the appellant committed the murder of Pooja, or whether the evidence and circumstances indicate that it was a case of suicide?

Treatment of the Issue by the Court

The following table demonstrates as to how the Court decided the issues

Authorities

The Supreme Court considered the following authorities:

Judgment

The Supreme Court analyzed the evidence and arguments presented by both sides. The Court noted that the case was based on circumstantial evidence, and there were two plausible scenarios: either Satish murdered Pooja, or Pooja committed suicide.

How each authority was viewed by the Court?

The Supreme Court relied on the authorities mentioned to emphasize the high standards required for conviction based on circumstantial evidence. The Court reiterated that the chain of circumstances must be complete, and the evidence must be inconsistent with the innocence of the accused. The Court also emphasized that the burden of proof lies on the prosecution to prove the guilt of the accused beyond reasonable doubt.

What weighed in the mind of the Court?

The Supreme Court’s decision to acquit Satish Nirankari was significantly influenced by the following factors:

• Authenticity of the Suicide Note: The Court gave considerable weight to the suicide note (Ex. P-3), which it concluded was written by Pooja. This was a crucial factor in determining that her death could have been a suicide.
• Lack of Conclusive Evidence of Murder: The Court found that the circumstantial evidence presented by the prosecution was not conclusive enough to prove that Satish had murdered Pooja. The Court noted the absence of eyewitnesses and the possibility that Pooja had committed suicide.
• Plausibility of the Appellant’s Version: The Court found Satish’s version of events, where Pooja decided to commit suicide due to fear of her family, to be plausible. The recovery of marriage-related items from the scene supported this version.
• Benefit of Doubt: The Court emphasized that in criminal cases, the burden of proof lies on the prosecution to prove the guilt of the accused beyond a reasonable doubt. When there are doubts about the prosecution’s case, the benefit of doubt must be given to the accused.
• Conduct of the Appellant: The Court noted that Satish’s actions after the incident, such as seeking help for Pooja and informing her family, did not align with the behavior of someone who had committed murder.

Fact:Law Ratio

Logical Reasoning:

The Court considered alternative interpretations, such as the possibility that Satish had murdered Pooja after she refused to marry him. However, the Court found that the prosecution had not presented sufficient evidence to support this interpretation. The Court also noted that the High Court’s reasons for convicting Satish were based on conjectures and assumptions, not on concrete evidence.

The Court’s reasoning was primarily based on the principle that the prosecution must prove the guilt of the accused beyond a reasonable doubt. The Court found that the prosecution had failed to meet this standard, and therefore, the appellant was entitled to an acquittal. The Court also emphasized that the benefit of doubt must be given to the accused in criminal cases.

The Court’s decision was unanimous, with both Justices A.K. Sikri and Ashok Bhushan agreeing on the acquittal of the appellant.

“In a case where there is no eyewitness and, which rests on circumstantial evidence, the prosecution is obligated to prove all those circumstances which leave no manner of doubts to establish the guilt of the accused person, i.e., chain of circumstances must be complete and must clearly point to the guilt of the accused.”

“In the present case, the circumstances which have been weighed by the courts below in arriving at the finding of guilt of the appellant are the following: (i) The appellant and deceased were alone together in a lonely house belonging to a third party which were lying vacant and was at the advance stage of construction.”

“We are, therefore, of the opinion that prosecution has not been able to prove the guilt of the appellant beyond reasonable doubt. As a consequence, this appeal is allowed setting aside the conviction of the appellant under Section 302 of the IPC.”

Key Takeaways

• In cases based on circumstantial evidence, the prosecution must prove guilt beyond a reasonable doubt. The chain of circumstances must be complete and point only to the guilt of the accused.
• The benefit of doubt must be given to the accused in criminal cases where there are doubts about the prosecution’s case.
• Suicide notes, if found to be genuine, can be crucial evidence in determining whether a death was a suicide or a murder.
• The conduct of the accused after an incident can be relevant in determining their guilt or innocence.
• Courts should not rely on conjectures and assumptions but on concrete evidence when deciding criminal cases.

Directions

The Supreme Court directed that the appellant, Satish Nirankari, be released forthwith if not wanted in any other case.

Specific Amendments Analysis

There is no specific amendment discussed in the judgment.

Development of Law

The ratio decidendi of this case is that in cases based on circumstantial evidence, the prosecution must prove the guilt of the accused beyond a reasonable doubt. The court also reiterated the importance of a complete chain of circumstances that points only to the guilt of the accused. This case reinforces the principle that the benefit of doubt must be given to the accused in criminal cases where there are doubts about the prosecution’s case.

Conclusion

The Supreme Court acquitted Satish Nirankari of the murder charges, holding that the prosecution failed to prove his guilt beyond a reasonable doubt. The Court emphasized that the case was based on circumstantial evidence, and there was a possibility that Pooja had committed suicide. The Court’s decision highlights the importance of the principle of “innocent until proven guilty” and the high standards required for conviction in criminal cases.