Supreme Court overturns conviction in murder case due to lack of conclusive evidence: Raja Naykar vs. State of Chhattisgarh (2024) INSC 56

Date of the Judgment: 24 January 2024

Citation: 2024 INSC 56

Judges: B.R. Gavai, J. and Sandeep Mehta, J.

Can a conviction for murder be upheld when the evidence is primarily circumstantial and the recovered weapon’s connection to the crime is not definitively established? The Supreme Court of India recently addressed this critical question in the case of Raja Naykar vs. State of Chhattisgarh. The court overturned the conviction of the appellant, emphasizing that a conviction cannot be based on suspicion alone, and the prosecution must prove guilt beyond a reasonable doubt. The judgment was delivered by a two-judge bench comprising Justice B.R. Gavai and Justice Sandeep Mehta.

Case Background

The case revolves around the death of Shiva, whose half-burnt body was discovered on October 21, 2009, near a temple in Chhattisgarh. The prosecution’s case was that Raja Naykar, the appellant, murdered Shiva because he believed Shiva was responsible for the death of his brother. According to the prosecution, on the night of October 21, 2009, Raja Naykar assaulted Shiva with a dagger, causing 24 stab wounds. He then allegedly wrapped the body in a blanket, transported it to the temple area with the help of other accused individuals, and attempted to burn it. The police investigation led to the arrest of Raja Naykar and others. The trial court convicted Raja Naykar for murder and destruction of evidence, a decision upheld by the High Court of Chhattisgarh. Raja Naykar then appealed to the Supreme Court.

Timeline:

Course of Proceedings

The case was initially tried in the Court of Additional Sessions Judge, Durg (Chhattisgarh). The Trial Judge convicted Raja Naykar for offences punishable under Sections 302 (murder) and 201 (causing disappearance of evidence) read with 120B (criminal conspiracy) of the Indian Penal Code, 1860 (IPC). Accused Nos. 2 to 4 were convicted under Sections 201 read with 120B of the IPC. Raja Naykar and the other accused then appealed to the High Court of Chhattisgarh. The High Court dismissed Raja Naykar’s appeal, upholding the trial court’s decision, but allowed the appeals of the other accused. Subsequently, Raja Naykar appealed to the Supreme Court.

Legal Framework

The judgment primarily revolves around the application of circumstantial evidence in criminal cases and the interpretation of Section 27 of the Indian Evidence Act, 1872. The relevant legal provisions are:

• ✓ Section 302 of the Indian Penal Code, 1860 (IPC): This section defines the punishment for murder.
• ✓ Section 201 of the Indian Penal Code, 1860 (IPC): This section deals with causing the disappearance of evidence of an offense or giving false information to screen the offender.
• ✓ Section 120B of the Indian Penal Code, 1860 (IPC): This section defines the punishment for criminal conspiracy.
• ✓ Section 27 of the Indian Evidence Act, 1872: This section allows the admissibility of statements made by an accused that lead to the discovery of a fact. The court referred to the Privy Council’s decision in Pulukuri Kotayya and others v. King-Emperor which held that only the part of the statement that leads to the discovery of a fact is admissible.

The court also emphasized the principles governing convictions based on circumstantial evidence, as laid down in Sharad Birdhichand Sarda vs. State of Maharashtra, stating that the circumstances must be fully established, consistent with the guilt of the accused, of a conclusive nature, and exclude every other hypothesis except the guilt of the accused. The court also emphasized that the accused ‘must be’ guilty and not merely ‘may be’ guilty.

Arguments

Appellant’s Arguments:

• ✓ The appellant argued that the trial court and the High Court erred in convicting him based on insufficient evidence.
• ✓ It was contended that the prosecution failed to establish the identity of the deceased, as the father and brother of the deceased could not identify the dead body.
• ✓ The appellant submitted that the findings of guilt were based on conjectures and surmises rather than concrete evidence.
• ✓ The appellant argued that the recovery of the dagger was not conclusive as it was from a place accessible to the public, and the blood on the dagger was not proven to be of the deceased.

State’s Arguments:

• ✓ The State argued that both the Trial Judge and the High Court correctly appreciated the evidence and found the appellant guilty.
• ✓ The State submitted that the recovery of the dagger at the instance of the appellant, which had human blood on it, was a crucial piece of evidence.
• ✓ The State contended that the recoveries made based on the appellant’s memorandum under Section 27 of the Indian Evidence Act, 1872, established his guilt beyond reasonable doubt.

[TABLE] of Submissions:

Issues Framed by the Supreme Court

The primary issue before the Supreme Court was:

1. Whether the conviction of the appellant based on circumstantial evidence and the recoveries made at his instance was sustainable in law.

Treatment of the Issue by the Court

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

Authorities

The Supreme Court relied on the following authorities:

Cases:

• ✓ Sharad Birdhichand Sarda vs. State of Maharashtra [(1984) 4 SCC 116] (Supreme Court of India): This case laid down the five golden principles for conviction based on circumstantial evidence. The court reiterated that the circumstances must be fully established, consistent with the guilt of the accused, of a conclusive nature, and exclude every other hypothesis except the guilt of the accused.
• ✓ Hanumant vs. State of Madhya Pradesh [(1952) 2 SCC 71] (Supreme Court of India): This case established the fundamental principles for cases based on circumstantial evidence, stating that the circumstances must be fully established and consistent only with the guilt of the accused.
• ✓ Mustkeem alias Sirajudeen v. State of Rajasthan [AIR 2011 SC 2769] (Supreme Court of India): This case held that the sole circumstance of recovery of a blood-stained weapon cannot form the basis of conviction unless it is connected with the murder of the deceased by the accused.
• ✓ Pulukuri Kotayya and others v. King-Emperor [1946 SCC OnLine 47] (Privy Council): This case clarified that under Section 27 of the Indian Evidence Act, 1872, only the part of the statement that leads to the discovery of a fact is admissible.

Statutes:

• ✓ Section 302 of the Indian Penal Code, 1860 (IPC): Punishment for murder.
• ✓ Section 201 of the Indian Penal Code, 1860 (IPC): Causing disappearance of evidence of an offense.
• ✓ Section 120B of the Indian Penal Code, 1860 (IPC): Criminal conspiracy.
• ✓ Section 27 of the Indian Evidence Act, 1872: Admissibility of statements leading to discovery.

[TABLE] of Authorities:

Judgment

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

How each authority was viewed by the Court?

• ✓ The Court relied on Sharad Birdhichand Sarda vs. State of Maharashtra [CITATION] to emphasize the necessity of fully established circumstances in cases based on circumstantial evidence.
• ✓ The Court used Hanumant vs. State of Madhya Pradesh [CITATION] to reinforce the principle that the circumstances must be consistent only with the guilt of the accused.
• ✓ The Court applied Mustkeem alias Sirajudeen v. State of Rajasthan [CITATION] to hold that the recovery of a blood-stained weapon alone is insufficient for conviction.
• ✓ The Court cited Pulukuri Kotayya and others v. King-Emperor [CITATION] to clarify the admissibility of statements under Section 27 of the Indian Evidence Act, 1872.

The Supreme Court overturned the conviction of Raja Naykar. The Court held that the prosecution’s case rested primarily on circumstantial evidence, which was not sufficient to prove the guilt of the accused beyond a reasonable doubt. The Court found that the recovery of the dagger, the main piece of evidence, was not conclusive as it was from a place accessible to the public, and the blood on the dagger was not proven to be of the deceased. The Court also noted that the prosecution failed to establish a clear link between the recovered weapon and the murder. The Court emphasized that suspicion, however strong, cannot replace proof beyond a reasonable doubt.

What weighed in the mind of the Court?

The Supreme Court’s decision was primarily influenced by the following factors:

• ✓ The lack of conclusive evidence linking the appellant to the crime.
• ✓ The failure of the prosecution to prove the guilt of the accused beyond a reasonable doubt.
• ✓ The fact that the recovered dagger was from a public place and the blood on it was not linked to the deceased.
• ✓ The established principles of circumstantial evidence, which require that the circumstances must be fully established, consistent with the guilt of the accused, and exclude every other hypothesis.
• ✓ The principle that suspicion, however strong, cannot replace proof beyond a reasonable doubt.

[TABLE] of Sentiment Analysis of Reasons:

Fact:Law Ratio Table:

Logical Reasoning:

The Court considered the prosecution’s reliance on the recovery of the dagger and the circumstantial evidence. However, the Court found that the recovery was not exclusive to the appellant, the blood on the dagger was not linked to the deceased, and the circumstances were not conclusive enough to establish guilt beyond a reasonable doubt. The Court also emphasized that suspicion, however strong, cannot replace proof beyond a reasonable doubt. The Court found that the prosecution failed to meet the high threshold of proof required in criminal cases, and therefore, the conviction could not be sustained.

The court did not discuss any alternative interpretations, as it was clear that the prosecution had failed to meet the burden of proof.

The reasons for the decision include:

• ✓ The circumstantial evidence was not conclusive.
• ✓ The recovery of the dagger was not exclusive to the appellant.
• ✓ The blood found on the dagger was not linked to the deceased.
• ✓ The prosecution failed to prove the guilt of the accused beyond a reasonable doubt.
• ✓ Suspicion cannot replace proof in criminal cases.

“It is settled law that the suspicion, however strong it may be, cannot take the place of proof beyond reasonable doubt.”

“An accused cannot be convicted on the ground of suspicion, no matter how strong it is. An accused is presumed to be innocent unless proved guilty beyond a reasonable doubt.”

“It is the duty of the prosecution to prove beyond all reasonable doubt that it is only the accused and the accused alone who has committed the crime. We find that the prosecution has utterly failed to do so.”

There were no majority or minority opinions as the judgment was unanimous.

Key Takeaways

The practical implications of this judgment are:

• ✓ Convictions cannot be based on suspicion, no matter how strong.
• ✓ The prosecution must prove guilt beyond a reasonable doubt.
• ✓ Circumstantial evidence must be conclusive and exclude every other hypothesis except the guilt of the accused.
• ✓ Recovery of a weapon alone is not sufficient for conviction unless it is directly linked to the crime and the accused.
• ✓ The accused is presumed innocent until proven guilty.

This judgment reinforces the high standard of proof required in criminal cases and emphasizes the importance of concrete evidence over mere suspicion. It will likely influence future cases involving circumstantial evidence and recoveries made at the instance of the accused.

Directions

The Supreme Court directed that the appellant, Raja Naykar, be released forthwith if he was not required in any other case.

Development of Law

The ratio decidendi of this case is that a conviction cannot be sustained solely on the basis of circumstantial evidence and the recovery of a weapon, without establishing a clear link between the weapon, the crime, and the accused. The judgment reinforces the principle that the prosecution must prove guilt beyond a reasonable doubt and that suspicion cannot replace proof. This case does not change any previous positions of law but reinforces the existing principles.

Conclusion

In conclusion, the Supreme Court overturned the conviction of Raja Naykar, holding that the prosecution failed to prove his guilt beyond a reasonable doubt. The Court emphasized that mere suspicion cannot replace proof and that the recovery of a weapon, without a clear link to the crime and the accused, is insufficient to sustain a conviction. This judgment reinforces the importance of conclusive evidence and the high standard of proof required in criminal cases.