Supreme Court Acquits Woman in Murder Case Based on Circumstantial Evidence: Mahila Roomabai Jatav vs. State of Madhya Pradesh (2019)

Date of the Judgment: 26 September 2019

Citation: Criminal Appeal No(s). 1989/2010

Judges: Hon’ble Mr. Justice Deepak Gupta and Hon’ble Mr. Justice Aniruddha Bose

Can a person be convicted solely on the basis of circumstantial evidence? The Supreme Court of India recently addressed this question in a criminal appeal where a woman was convicted for the murder of her husband. The court examined the evidence, including the “last seen” theory, alleged motive, and recovery of a weapon, to determine if the conviction was justified. The judgment was delivered by a two-judge bench comprising Hon’ble Mr. Justice Deepak Gupta and Hon’ble Mr. Justice Aniruddha Bose.

Case Background

The appellant, Mahila Roomabai Jatav, was married to Shivcharan, the elder brother of Chironji Jatav (PW1). They lived in the same compound but in separate huts. On March 13, 1995, at around 3:00 AM, Chironji Jatav saw Roomabai and Shivcharan going outside, stating they were going to defecate. Roomabai returned alone, and when asked about Shivcharan, she said he would come later. When Shivcharan did not return, the family became suspicious. They suspected Roomabai of having an illicit relationship with one Ramesh of the same village. They later alleged that Roomabai confessed that Ramesh had killed Shivcharan and thrown his body in a well. The body was later found in a well about 1 km away.

Timeline:

Course of Proceedings

The Trial Court convicted both Roomabai and Ramesh for murder under Section 302 read with Section 120B of the Indian Penal Code, 1860, and for destruction of evidence under Section 201 of the Indian Penal Code, 1860. The High Court acquitted Ramesh due to lack of evidence, but upheld Roomabai’s conviction based on the “last seen” theory and her alleged confession. The High Court also believed the recovery of an axe with blood stains and shoes from Roomabai’s house.

Legal Framework

The case involves the following sections of the Indian Penal Code, 1860:

• Section 302 of the Indian Penal Code, 1860: This section defines the punishment for murder.
• Section 120B of the Indian Penal Code, 1860: This section deals with the punishment for criminal conspiracy.
• Section 201 of the Indian Penal Code, 1860: This section deals with causing disappearance of evidence of offence, or giving false information to screen offender.

The judgment also discusses the principles of circumstantial evidence, which requires that all circumstances should form an unbroken chain leading only to the guilt of the accused. If there is a possibility of the offense being committed by someone else, the benefit of doubt must be given to the accused.

Arguments

The prosecution argued that:

• Motive: Roomabai had an illicit relationship with Ramesh, which was the motive for the murder.
• Last Seen: Roomabai was last seen with her husband, Shivcharan, before his death.
• Recovery: A blood-stained axe was recovered from Roomabai’s house.
• Extra-Judicial Confession: Roomabai confessed that Ramesh had killed Shivcharan and thrown his body in a well.

The defense argued that:

• Motive: The witness (PW1) admitted that Shivcharan was present with Roomabai and Ramesh a day before the incident, making the motive doubtful.
• Last Seen: It is not unusual for a husband and wife to be seen together.
• Recovery: There were no independent witnesses to the recovery of the axe, making it doubtful.
• Extra-Judicial Confession: Since Ramesh was acquitted, the confession is unreliable.

The innovativeness of the argument lies in the defense’s ability to question the prosecution’s circumstantial evidence by highlighting the lack of independent witnesses and the implausibility of the motive.

Issues Framed by the Supreme Court

The Supreme Court considered the following issues:

1. Whether the circumstantial evidence was sufficient to convict the appellant for the murder of her husband.

Treatment of the Issue by the Court

Authorities

The court did not explicitly cite any specific case laws or books in the judgment. The judgment primarily focused on the facts and circumstances of the case and the principles of circumstantial evidence.

Judgment

How each authority was viewed by the Court?

The court relied on the principles of circumstantial evidence to assess the case. The court stated that the circumstances should form an unbroken chain leading only to the guilt of the accused. The court found that the chain of circumstances was broken and did not point towards the guilt of the accused.

What weighed in the mind of the Court?

The Supreme Court was primarily influenced by the lack of a strong chain of circumstantial evidence. The court emphasized that the prosecution failed to prove the motive, the last seen theory was not sufficient to establish guilt, the recovery of the axe was doubtful, and the extra-judicial confession was unreliable. The court was also influenced by the fact that no independent witnesses were present for the recovery of the axe and that the police did not follow proper procedure in the village. These factors led the court to conclude that the prosecution failed to prove the guilt of the accused beyond a reasonable doubt.

The Court stated that, “The law with regard to circumstantial evidence is well settled that all the circumstances should be linked together in such a manner that they form an unbroken chain which leads to only one unerring conclusion, that is, the guilt of the accused.” The Court also noted, “If there is any chance of the offence being committed by any other person then the benefit has to be given to the accused.” Further, the Court observed, “We, therefore, are left only with one circumstance of last seen and we do not feel this circumstance alone is sufficient to hold the accused guilty of the offences of which she has been convicted.”

Key Takeaways

• Circumstantial evidence must form an unbroken chain to prove guilt.
• The “last seen” theory alone is not sufficient for conviction.
• Recovery of evidence must be supported by independent witnesses.
• Extra-judicial confessions must be reliable and corroborated.
• The benefit of doubt must be given to the accused if there is a chance of the offense being committed by someone else.

Directions

The Supreme Court allowed the appeal and set aside the judgment of the High Court and the Trial Court. The appellant was acquitted, and her bail bonds were discharged.

Development of Law

The ratio decidendi of this case is that circumstantial evidence must form an unbroken chain leading only to the guilt of the accused. The case reinforces the principle that the “last seen” theory alone is not sufficient for conviction and that the benefit of doubt must be given to the accused if there is a possibility of the offense being committed by another person. This case does not change the previous position of law but rather emphasizes the importance of a strong chain of evidence in cases based on circumstantial evidence.

Conclusion

The Supreme Court acquitted Mahila Roomabai Jatav, overturning her conviction for the murder of her husband. The court found that the circumstantial evidence presented by the prosecution was insufficient to prove her guilt beyond a reasonable doubt. The court emphasized the importance of a strong chain of evidence in cases based on circumstantial evidence and the need for independent witnesses to support the recovery of evidence. The judgment underscores the principle that the benefit of doubt must be given to the accused.