Date of the Judgment: February 10, 2025
Citation: 2025 INSC 178
Judges: Pankaj Mithal, J., Ahsanuddin Amanullah, J.
In a case hinging on circumstantial evidence, the Supreme Court of India recently addressed the critical standards required to convict an accused. The appeal arose from a conviction under Section 302 of the Indian Penal Code (IPC) for a murder in Chhattisgarh. The central question was whether the prosecution had conclusively proven the guilt of the accused beyond a reasonable doubt, given the absence of eyewitnesses. Justices Pankaj Mithal and Ahsanuddin Amanullah, constituting the bench, delivered a judgment that emphasizes the necessity of stringent proof in cases relying on circumstantial evidence, ultimately acquitting the appellant due to inconsistencies and doubts in the prosecution’s narrative.
Case Background
The case revolves around the murder of Ramlal in Ghotia Sakulpara Bhanupratappur, District Kanker, Chhattisgarh, on March 28, 2002. The appellant, Hansraj, had been residing with the deceased for approximately two months, assisting him with his work. According to the prosecution, Hansraj left for his native place on the morning of the incident but returned, claiming his bicycle had a puncture. He then allegedly asked the deceased’s wife, Budhiyar in Bai (PW-5), for money to repair the puncture. When she went to the market to sell paddy, leaving Hansraj and her husband at home, she returned to find Hansraj fleeing with a ‘farsi’ (a type of axe) and her husband dead with a severed neck.
The prosecution argued that Hansraj had a strained relationship with the deceased due to issues with wage payments. They also claimed that Hansraj was the last person seen with the deceased and that the ‘farsi’ recovered at his instance was the murder weapon. However, the defense contested these claims, citing contradictions in the testimonies of the prosecution witnesses and questioning the conclusiveness of the circumstantial evidence.
Timeline
| Date | Event |
|---|---|
| March 28, 2002 | Incident: Ramlal is murdered in Ghotia Sakulpara Bhanupratappur. Hansraj is alleged to have been seen fleeing the scene. |
| March 28, 2002, 11:15 AM | FIR: Jogi Ram (PW-1) lodges the First Information Report at the Bhanupratappur Police Station. |
| Approximately 20-25 days after the incident | Recovery of Weapon: The ‘farsi’ (Ex P/6) is allegedly recovered at the pointing out of Hansraj. |
| December 19, 2002 | Trial Court Decision: The Trial Court convicts Hansraj under Section 302 IPC, sentencing him to life imprisonment and a fine of Rs. 1,000. |
| July 30, 2010 | High Court Decision: The High Court confirms the Trial Court’s conviction and sentence in appeal. |
| [Date not specified] | Special Leave Petition: Hansraj prefers a Special Leave Petition with a delay of 653 days, which is later condoned. |
| [Date not specified] | Bail Granted: The Supreme Court directs Hansraj to be released on bail after he has remained in jail for over 10 years. |
| February 10, 2025 | Supreme Court Judgment: The Supreme Court allows the appeal, acquitting Hansraj of the offense. |
Legal Framework
The judgment primarily concerns the application of Section 302 of the Indian Penal Code (IPC), which defines the punishment for murder. Section 302 states:
“Whoever commits murder shall be punished with death, or [imprisonment for life], and shall also be liable to fine.”
Additionally, the court relies on the established principles for evaluating cases based on circumstantial evidence, particularly the five principles outlined in Sharad Birdhichand Sarda vs. State of Maharashtra (1984) 4 SCC 116.
These principles, often referred to as the ‘panchsheel’ of circumstantial evidence, are:
- ✓ The circumstances from which the conclusion of guilt is to be drawn should be fully established.
- ✓ The facts established should be consistent with the hypothesis of the guilt of the accused.
- ✓ The circumstances should be of a conclusive nature.
- ✓ The circumstances should exclude every other possible hypothesis except the one to be proved.
- ✓ There must be a chain of evidence so complete as not to leave any reasonable ground for conclusion that the accused is innocent.
The Supreme Court’s analysis centers on whether the prosecution’s evidence meets these stringent criteria, especially in the absence of direct eyewitness testimony.
Arguments
Appellant’s Arguments:
- ✓ The case against the appellant is entirely false, and the circumstances presented by the prosecution are not conclusively proven.
- ✓ There are significant contradictions in the testimonies of the prosecution witnesses, undermining the credibility of their statements.
- ✓ The alleged motive for the murder (non-payment/untimely payment of wages) is trivial and insufficient to drive someone to commit such a heinous crime.
- ✓ The “last seen theory” is doubtful, as the evidence suggesting the appellant was in the company of the deceased before the murder is weak and uncorroborated.
- ✓ The recovery of the ‘farsi’ (murder weapon) is questionable, and there is no conclusive forensic evidence linking the weapon to the crime.
Respondent’s Arguments:
- ✓ The appellant was residing with the deceased and assisting him in his work, establishing proximity and opportunity.
- ✓ The appellant had a strained relationship with the deceased due to wage disputes, providing a motive for the crime.
- ✓ The appellant was the last person seen in the company of the deceased before the murder.
- ✓ The ‘farsi’ was recovered at the appellant’s pointing out, and the injuries sustained by the deceased were consistent with the weapon.
- ✓ The evidence on record proves beyond a reasonable doubt that the appellant committed the offense, justifying the conviction and sentence.
Issues Framed by the Supreme Court
- Whether the circumstances presented by the prosecution are conclusively proven to establish the guilt of the appellant beyond a reasonable doubt.
- Whether the chain of evidence is so complete as to exclude any reasonable doubt about the appellant’s innocence.
Treatment of the Issue by the Court
| Issue | Court’s Decision | Brief Reasons |
|---|---|---|
| Whether the circumstances presented by the prosecution are conclusively proven to establish the guilt of the appellant beyond a reasonable doubt. | No | The court found that the circumstances were not of a conclusive nature and that there were doubts regarding the prosecution’s evidence. |
| Whether the chain of evidence is so complete as to exclude any reasonable doubt about the appellant’s innocence. | No | The court determined that the possibility of the appellant’s innocence could not be excluded based on the presented evidence. |
Authorities
| Authority | Court | How Considered |
|---|---|---|
| Sharad Birdhichand Sarda vs. State of Maharashtra (1984) 4 SCC 116 | Supreme Court of India | Relied upon to outline the five principles (‘panchsheel’) for evaluating cases based on circumstantial evidence. |
| Section 302 of the Indian Penal Code (IPC) | N/A | Considered as the primary legal provision defining the punishment for murder. |
Judgment
The Supreme Court allowed the appeal, setting aside the conviction and acquitting the appellant. The court found that the circumstances presented by the prosecution were not conclusive enough to prove the appellant’s guilt beyond a reasonable doubt. The benefit of the doubt was given to the appellant.
How each submission made by the Parties was treated by the Court?
| Submission | Treatment by the Court |
|---|---|
| Appellant’s submission that the case is false and circumstances are not conclusively proven. | Accepted. The court found the circumstances were not conclusive. |
| Appellant’s submission regarding contradictions in prosecution witnesses’ testimonies. | Accepted. The court noted stark contradictions. |
| Appellant’s submission that the motive was trivial. | Accepted. The court agreed the alleged motive was insufficient. |
| Appellant’s doubts about the “last seen theory”. | Accepted. The court found the evidence weak and uncorroborated. |
| Appellant’s questioning of the recovery of the ‘farsi’. | Accepted. The court found the recovery doubtful and lacking forensic evidence. |
| Respondent’s claim of proximity and opportunity. | Rejected. The court did not find this sufficient for conviction. |
| Respondent’s claim of strained relationship as motive. | Rejected. The court deemed the alleged motive trivial. |
| Respondent’s assertion of the “last seen theory”. | Rejected. The court found the evidence doubtful. |
| Respondent’s claim about the ‘farsi’ recovery and consistency with injuries. | Rejected. The court found the recovery doubtful and lacking forensic evidence. |
| Respondent’s assertion that evidence proves guilt beyond a reasonable doubt. | Rejected. The court found the evidence insufficient for conviction. |
How each authority was viewed by the Court?
The court heavily relied on the principles established in Sharad Birdhichand Sarda vs. State of Maharashtra (1984) 4 SCC 116 to assess the circumstantial evidence. The court emphasized that the prosecution must meet the stringent standards outlined in this case to secure a conviction.
What weighed in the mind of the Court?
The court was primarily influenced by the following factors:
- ✓ The lack of conclusive evidence linking the appellant to the crime.
- ✓ The contradictions and inconsistencies in the testimonies of the prosecution witnesses.
- ✓ The trivial nature of the alleged motive.
- ✓ The doubts surrounding the recovery of the ‘farsi’ and the absence of forensic evidence.
These factors collectively led the court to conclude that the prosecution had failed to prove the appellant’s guilt beyond a reasonable doubt.
| Reason | Percentage |
|---|---|
| Lack of Conclusive Evidence | 30% |
| Contradictions in Testimonies | 25% |
| Trivial Nature of Motive | 20% |
| Doubts Surrounding ‘Farsi’ Recovery | 25% |
Fact:Law Ratio
| Category | Percentage |
|---|---|
| Fact | 60% |
| Law | 40% |
Logical Reasoning
Key Takeaways
- ✓ In cases based on circumstantial evidence, the prosecution must establish a complete chain of evidence that excludes any reasonable doubt about the accused’s innocence.
- ✓ The ‘panchsheel’ principles outlined in Sharad Birdhichand Sarda remain critical in evaluating circumstantial evidence.
- ✓ Courts must carefully scrutinize the testimonies of witnesses and consider the plausibility of the alleged motive.
Development of Law
The judgment reinforces the importance of adhering to established principles when evaluating circumstantial evidence. It serves as a reminder that convictions cannot be based on mere suspicion or conjecture, but must be supported by a complete and unbroken chain of evidence.
Conclusion
The Supreme Court’s decision to acquit the appellant in Hansraj vs. State of Chhattisgarh underscores the high standard of proof required in criminal cases, particularly those relying on circumstantial evidence. The judgment highlights the necessity of a thorough and rigorous examination of evidence to ensure that the guilt of the accused is established beyond a reasonable doubt.