Supreme Court acquits Guna Mahto in wife’s murder case: A case of circumstantial evidence (16 March 2023)

Date of the Judgment: 16th March, 2023
Citation: [Not Available in Source]

Judges: Justice B.R. Gavai and Justice Sanjay Karol
Can a conviction be sustained solely on the basis of circumstantial evidence, especially when the investigation is incomplete and key witnesses are not examined? The Supreme Court of India recently addressed this crucial question in the case of Guna Mahto vs. State of Jharkhand. The Court overturned the conviction of Guna Mahto, who was accused of murdering his wife, emphasizing that suspicion, however strong, cannot replace concrete evidence. The judgment, delivered by a bench of Justice B.R. Gavai and Justice Sanjay Karol, highlights the importance of a thorough investigation and the need for the prosecution to prove guilt beyond a reasonable doubt, especially in cases relying on circumstantial evidence.

Case Background

The case revolves around the death of Smt. Deomatiya Devi, wife of the appellant, Guna Mahto. On 13th August 1988, her body was discovered in a well in their village. The prosecution alleged that Guna Mahto murdered his wife and then disposed of her body in the well to conceal the crime. Subsequently, Guna Mahto reported his wife as missing to the police. The police registered a case (P.S. Case No. 35/1988) at Manika Police Station, Jharkhand, and after investigation, presented a charge sheet before the trial court.

Timeline

Course of Proceedings

The Trial Court convicted Guna Mahto under Section 302 (murder) and Section 201 (causing disappearance of evidence) of the Indian Penal Code, 1860. The High Court of Jharkhand upheld this conviction, despite noting that the Investigating Officer was not examined by the prosecution. The High Court primarily relied on the testimonies of Banaudhi Mahto (PW-2), Samodhi Yadav (PW-9), and Nandish Yadav (PW-10). Aggrieved by this, Guna Mahto filed an appeal before the Supreme Court.

Legal Framework

The Supreme Court referred to the principles governing cases based on circumstantial evidence, as laid down in the case of Sharad Birdhichand Sarda v. State of Maharashtra, (1984) 4 SCC 116. The Court emphasized that circumstantial evidence must meet stringent criteria to establish guilt:

• The circumstances from which guilt is inferred must be fully established.
• The facts must be consistent only with the hypothesis of the accused’s guilt.
• The circumstances should be conclusive and exclude every other possible hypothesis.
• There must be a complete chain of evidence that leaves no reasonable doubt about the accused’s guilt.

The Court also considered 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 offence.

Arguments

The prosecution argued that Guna Mahto had murdered his wife and then disposed of her body in the well. The prosecution relied on the testimonies of Banaudhi Mahto (PW-2), Samodhi Yadav (PW-9), and Nandish Yadav (PW-10) to establish the guilt of the accused. They also relied on the fact that the accused had lodged a false report of his wife being missing.

The defense argued that the prosecution had failed to establish the guilt of the accused beyond a reasonable doubt. They emphasized that the testimonies of the witnesses were unreliable and based on hearsay. Further, the Investigating Officer, a key witness, was not examined by the prosecution.

Issues Framed by the Supreme Court

The Supreme Court did not explicitly frame issues in a separate section. However, the core issue before the Court was:

1. Whether the prosecution had proved the guilt of the accused beyond a reasonable doubt based on the circumstantial evidence presented.

The court also considered the sub-issue of whether the non-examination of the Investigating Officer was fatal to the prosecution’s case.

Treatment of the Issue by the Court

Authorities

The Court relied on the following authorities:

• Sharad Birdhichand Sarda v. State of Maharashtra, (1984) 4 SCC 116 – This case laid down the principles for evaluating circumstantial evidence.
• Shivaji Sahabrao Bobade v. State of Maharashtra [(1973) 2 SCC 793 – This case clarified the difference between “may be” and “must be” in establishing guilt.
• Venkatesh v. State of Karnataka, 2022 SCC OnLine SC 765 – This case reiterated that suspicion cannot form the basis of guilt.
• Shatrughna Baban Meshram v. State of Maharashtra, (2021) 1 SCC 596 – This case emphasized that the prosecution must prove its case beyond a reasonable doubt.
• Pappu v. State of Uttar Pradesh, (2022) 10 SCC 321 – This case highlighted the importance of concrete evidence in establishing guilt.
• Hanumant Govind Nargundkar v. State of M.P. (1952) 2 SCC 71 – This case underscores the importance of avoiding miscarriage of justice and giving the benefit of doubt to the accused.
• Ramaphupala Reddy v. State of Andhra Pradesh, (1970) 3 SCC 474 – This case addresses the exceptional circumstances where the Supreme Court can interfere with concurrent findings of facts.
• Balak Ram v. State of U.P., (1975) 3 SCC 219 – This case addresses the exceptional circumstances where the Supreme Court can interfere with concurrent findings of facts.
• Bhoginbhai Hirjibhai V. State of Gujarat, (1983) 3 SCC 217 – This case addresses the exceptional circumstances where the Supreme Court can interfere with concurrent findings of facts.

Judgment

The Supreme Court analyzed the evidence and the testimonies of the witnesses. The Court noted that “When we examine the testimony of Banaudhi Mahto (PW-2), father of the deceased, we notice him not to have stated anything against the accused in relation to the crime.” The Court further observed that the testimony of Samodhi Yadav (PW-9) was hearsay and that of Nandish Yadav (PW-10) was vague and unspecific. The Court also emphasized that “the circumstances linking the accused to the crime are not proven at all, much less beyond reasonable doubt.” The Court also held that “It is our bounden duty to ensure that miscarriage of justice is avoided at all costs and the benefit of doubt, if any, given to the accused.”

What weighed in the mind of the Court?

The Supreme Court was primarily influenced by the lack of concrete evidence and the unreliable nature of the testimonies presented by the prosecution. The non-examination of the Investigating Officer was a critical factor that weighed against the prosecution’s case. The Court emphasized that suspicion, however strong, cannot replace the need for the prosecution to prove the guilt of the accused beyond a reasonable doubt. The Court also highlighted the importance of avoiding miscarriage of justice and giving the benefit of the doubt to the accused.

Logical Reasoning

Key Takeaways

• In cases based on circumstantial evidence, the prosecution must establish a complete chain of evidence that points only towards the guilt of the accused.
• Suspicion, however strong, cannot replace concrete evidence.
• The non-examination of a key witness, such as the Investigating Officer, can be fatal to the prosecution’s case.
• Courts must ensure that miscarriage of justice is avoided and that the benefit of doubt is given to the accused.

Directions

The Supreme Court set aside the orders of conviction and sentence passed by the lower courts. The appellant, Guna Mahto, who was on bail, was discharged from his bail bond.

Development of Law

The ratio decidendi of this case is that in cases based on circumstantial evidence, the prosecution must establish a complete chain of evidence that points only towards the guilt of the accused, and suspicion, however strong, cannot replace concrete evidence. The Court reiterated the principles laid down in Sharad Birdhichand Sarda v. State of Maharashtra, (1984) 4 SCC 116. There is no change in the previous position of law, but the court has emphasized the importance of the existing principles.

Conclusion

The Supreme Court’s decision in Guna Mahto vs. State of Jharkhand highlights the critical importance of a thorough investigation and the need for the prosecution to prove guilt beyond a reasonable doubt, especially in cases relying on circumstantial evidence. The Court’s emphasis on the principles of justice and the avoidance of miscarriage of justice serves as a reminder of the high standards required in criminal proceedings.