Supreme Court Acquits Accused in Murder Case Due to Lack of Evidence: Sharanappa vs. State of Karnataka (2023)

Date of the Judgment: 4 October 2023

Citation: 2023 INSC 904

Judges: Abhay S. Oka, J., Pankaj Mithal, J.

Can a conviction be sustained solely on the basis of circumstantial evidence if the chain of circumstances is not fully established? The Supreme Court of India recently addressed this question in a criminal appeal where the accused was acquitted due to lack of sufficient evidence. The Court emphasized the importance of proving every link in the chain of circumstances to establish guilt beyond a reasonable doubt. The judgment was delivered by a division bench of Justices Abhay S. Oka and Pankaj Mithal.

Case Background

The appellant, Sharanappa, married Meenakshi in 2003. He worked as a coolie in Mangalore. About 3-4 months before the incident, Sharanappa and Meenakshi began living together in a rented room. On May 28, 2004, a witness, Alfred Mathai, claimed to have seen Sharanappa and Meenakshi near a bus stop. On May 30, 2004, Meenakshi’s body was found in a decomposed state. The prosecution alleged that Sharanappa had informed his father-in-law on May 28, 2004, that Meenakshi was missing, but he did not file a missing person complaint until May 31, 2004. The First Information Report (FIR) was filed on June 1, 2004, based on a complaint by Sharanappa’s father-in-law, alleging that Sharanappa suspected Meenakshi of adultery, which was the motive for her murder.

Timeline

Course of Proceedings

The Trial Court convicted Sharanappa for offences under Section 302 (murder) and Section 201 (causing disappearance of evidence) of the Indian Penal Code, 1860 (IPC). The High Court upheld this conviction. Sharanappa then appealed to the Supreme Court of India.

Legal Framework

The case primarily revolves around Section 302 of the Indian Penal Code, 1860, which defines the punishment for murder, and Section 201 of the Indian Penal Code, 1860, which deals with causing disappearance of evidence of an offense.

Section 302 of the Indian Penal Code, 1860 states: “Punishment for murder.—Whoever commits murder shall be punished with death, or 1[imprisonment for life], and shall also be liable to fine.”

Section 201 of the Indian Penal Code, 1860 states: “Causing disappearance of evidence of offence, or giving false information to screen offender.—Whoever, knowing or having reason to believe that an offence has been committed, causes any evidence of the commission of that offence to disappear, with the intention of screening the offender from legal punishment, or with that intention gives any information respecting the offence which he knows or believes to be false, shall be punished with imprisonment of either description for a term which may extend to seven years, and shall also be liable to fine; or, if the offence which he knows or believes to have been committed is punishable with death, shall be punished with imprisonment of either description for a term which may extend to ten years, and shall also be liable to fine; or, if the offence which he knows or believes to have been committed is punishable with imprisonment for life, shall be punished with imprisonment of either description for a term which may extend to seven years, and shall also be liable to fine.”

The case is based on circumstantial evidence, meaning there was no direct witness to the crime. In such cases, the prosecution must establish a complete chain of circumstances that points towards the guilt of the accused.

Arguments

Appellant’s Arguments:

• The primary argument of the appellant was that the prosecution failed to establish the chain of circumstances necessary for a conviction.
• The appellant’s counsel argued that the testimony of PW-3, Alfred Mathai, who claimed to have seen the appellant with the deceased, was unreliable. The counsel pointed out that PW-3’s statements in court were inconsistent with his earlier statements to the police under Section 161 of the Code of Criminal Procedure, 1973 (CrPC).
• The counsel also argued that the alleged recovery of the knife, the supposed murder weapon, at the instance of the appellant was not proven. The witnesses to the recovery, PW-4 and PW-5, did not support the prosecution’s version of events.
• The appellant contended that the delay in filing a missing person complaint was not sufficient to establish guilt.

Respondent’s Arguments:

• The State argued that the Trial Court and the High Court correctly analyzed the evidence of PW-3 and found his testimony to be reliable.
• The State contended that the appellant’s failure to report his wife missing between May 28 and May 31, 2004, was a crucial circumstance against him. The State argued that the appellant only filed a missing complaint after learning about the discovery of his wife’s body.

Issues Framed by the Supreme Court

The Supreme Court considered the following issues:

1. Whether the prosecution had successfully established the chain of circumstances to prove the guilt of the accused?
2. Whether the testimony of PW-3 Alfred Mathai was reliable?
3. Whether the recovery of the weapon at the instance of the appellant was proved?

Treatment of the Issue by the Court

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

Authorities

The Supreme Court did not cite any specific cases or legal provisions other than the ones mentioned above.

Judgment

How each submission made by the Parties was treated by the Court?

How each authority was viewed by the Court?

• The Court considered Section 302 of the Indian Penal Code, 1860, and found that the prosecution had not provided sufficient evidence to prove the charge of murder.
• The Court considered Section 201 of the Indian Penal Code, 1860, and found that the prosecution had not provided sufficient evidence to prove the charge of causing disappearance of evidence.
• The Court considered the statement of PW-3 under Section 161 of the Code of Criminal Procedure, 1973, to highlight the inconsistencies in his testimony.

What weighed in the mind of the Court?

The Supreme Court’s decision to acquit the appellant was primarily influenced by the lack of credible evidence presented by the prosecution. The Court emphasized that in cases based on circumstantial evidence, every link in the chain of circumstances must be proven beyond a reasonable doubt. The unreliability of the key witness, PW-3, and the failure to prove the recovery of the alleged murder weapon were critical factors that weighed heavily in the Court’s decision. The Court also noted that the delay in filing a missing person report, while suspicious, was not sufficient evidence to convict the appellant.

The Court’s reasoning was based on the principle that in cases of circumstantial evidence, the prosecution must prove each circumstance beyond reasonable doubt, and the circumstances must form a complete chain that points towards the guilt of the accused. The Court noted, “Therefore, it is impossible to believe his testimony. Hence, the theory of the prosecution about the last seen together must fail.” The Court also stated, “Only on the basis of the third circumstance based on the conduct of the appellant, the appellant cannot be convicted.” The Court further observed, “Thus, it is crystal clear that what is stated by the PW-3 Alfred Mathai in his examination-in-chief is a complete improvement.”

Key Takeaways

• In cases based on circumstantial evidence, the prosecution must establish a complete chain of circumstances that points towards the guilt of the accused beyond a reasonable doubt.
• The testimony of witnesses must be consistent and reliable. Inconsistencies and improvements in testimony can lead to it being deemed unreliable.
• The recovery of a weapon or other evidence must be proven through credible witnesses.
• Mere suspicion or questionable conduct is not sufficient to convict a person.
• The burden of proof lies on the prosecution to prove the guilt of the accused.

Directions

The Supreme Court directed that the appellant be acquitted of all charges and that his bail bonds be cancelled.

Development of Law

The ratio decidendi of this case is that in a case based on circumstantial evidence, the prosecution must prove each circumstance beyond a reasonable doubt, and the circumstances must form a complete chain that points towards the guilt of the accused. This judgment reinforces the principle that the benefit of doubt must always go to the accused, and mere suspicion is not enough for conviction.

Conclusion

The Supreme Court’s decision to acquit Sharanappa highlights the importance of a robust chain of evidence in cases based on circumstantial evidence. The Court’s emphasis on the unreliability of the key witness and the failure to prove the recovery of the weapon underscores the high standard of proof required in criminal cases. This judgment serves as a reminder that mere suspicion or questionable conduct is not sufficient for conviction, and the prosecution must prove its case beyond a reasonable doubt.