Introduction
Date of the Judgment: May 07, 2025
Citation: (2025) INSC 702
Judges: Vikram Nath, J., Sanjay Karol, J., Sandeep Mehta, J.
In a shocking turn of events, the Supreme Court of India has overturned the conviction of an accused in a rape and murder case, citing a “shabby and perfunctory investigation.” The case, Ramkirat Munilal Goud vs. State of Maharashtra, involved the gruesome death of a 3-year-old girl. Despite the heinous nature of the crime, the Supreme Court found that the prosecution’s case was built on weak circumstantial evidence and a flawed investigation, leading to the acquittal of the accused after nearly 12 years of incarceration. This judgment highlights the critical importance of thorough and unbiased investigations in ensuring justice. The bench comprised Justices Vikram Nath, Sanjay Karol, and Sandeep Mehta.
Case Background
The case began with a complaint filed by Manoj Bhaskar Sadavarte (PW-1), a painter residing in Thane, Maharashtra. On September 30, 2013, Sadavarte’s 3-year-old daughter went missing from their home. According to the complaint, Sadavarte and his mother left the child alone at approximately 10:30 A.M. When Sadavarte returned around 10:45 A.M., his daughter was nowhere to be found. A frantic search ensued, but the child remained missing.
Sadavarte reported the incident to the Kasarvadavali Police Station, leading to the registration of FIR No. I-306/2013 under Section 363 of the Indian Penal Code (IPC). The initial investigation was led by Assistant Police Inspector (API) Vikas Sarjerao Lokre (PW-16), who prepared a spot panchnama on October 1, 2013. The panchnama documented the location where the child was last seen and included statements from neighbors who claimed to have seen the child playing with a dog.
On October 2, 2013, the child’s body was discovered in a muddy water pond about one kilometer from the watchmen chawl. The body was in a highly decomposed state and was sent to Civil Hospital, Thane, and subsequently to J.J. Hospital for a post-mortem examination. The post-mortem report revealed numerous injuries on the child’s genitalia and skull, with the medical board concluding that the head injury was sufficient to cause death.
The investigation was then transferred to Deputy Superintendent of Police Mandar Vasant Dharmadhikari (PW-18) on October 3, 2013. The accused, Ramkirat Munilal Goud, was arrested on the same day. The prosecution claimed that Goud confessed to the crime and that blood-stained soil and stone slabs were found in his room. However, DNA profiling tests were inconclusive.
Timeline:
| Date | Event |
|---|---|
| September 30, 2013, 10:30 A.M. | Manoj Sadavarte and his mother leave the child alone at their residence. |
| September 30, 2013, 10:45 A.M. | Sadavarte returns home and discovers his daughter is missing. |
| September 30, 2013 | FIR No. I-306/2013 is registered at Kasarvadavali Police Station. |
| October 1, 2013 | API Vikas Sarjerao Lokre (PW-16) prepares the spot panchnama. |
| October 2, 2013 | The child’s body is recovered from a pond approximately one kilometer from the watchmen chawl. |
| October 3, 2013 | Investigation transferred to DSP Mandar Vasant Dharmadhikari (PW-18). |
| October 3, 2013 | Accused Ramkirat Munilal Goud is arrested. |
| October 8, 2013 | Allegedly incriminating materials recovered from the accused’s room. |
| March 5, 2019 | Trial Court convicts the accused. |
| March 8, 2019 | Trial Court sentences the accused. |
| November 25, 2021 | High Court of Judicature at Bombay upholds the conviction and death sentence. |
| May 7, 2025 | Supreme Court overturns the conviction and acquits the accused. |
Legal Framework
The legal framework relevant to this case primarily involves the following sections and acts:
- Section 363 of the Indian Penal Code (IPC): Deals with the offence of kidnapping.
- Section 302 of the IPC: Addresses the punishment for murder.
- Section 376(2)(i) of the IPC: Concerns rape committed by a person in a position of authority or trust.
- Section 201 of the IPC: Relates to causing disappearance of evidence of an offence or giving false information to screen an offender.
- Sections 4 and 8 of the Protection of Children from Sexual Offences Act, 2013: Specifies offences and punishments for sexual assault against children.
These provisions outline the legal definitions, elements, and penalties associated with the crimes for which the accused was charged.
Arguments
Appellant’s Arguments
- Unreliable Last Seen Evidence: The defense argued that the testimonies of witnesses claiming to have seen the accused with the victim were inconsistent and unreliable. The witnesses did not come forward promptly, raising doubts about their credibility.
- Doubtful Extra-Judicial Confession: The defense contended that the extra-judicial confession allegedly made by the accused to his supervisor was weak and lacked credibility. The supervisor’s initial statement did not mention any confession, and it was only introduced later through leading questions.
- Inconclusive FSL Report: The defense argued that the Forensic Science Laboratory (FSL) report linking soil found on the accused’s shoes to the pond where the victim’s body was found was vague and inconclusive. The defense pointed out that the prosecution failed to establish that the soil was unique to the pond area.
- Flawed Investigation: The defense highlighted that forensic samples were collected from numerous watchmen but were never presented in court, suggesting that these reports did not support the prosecution’s case.
Respondent’s Arguments
- Chain of Circumstantial Evidence: The prosecution argued that the guilt of the accused was established through a complete chain of circumstantial evidence, including motive, last seen together, extra-judicial confession, and scientific evidence.
- Reliable Witnesses: The prosecution asserted that the witnesses had no animosity towards the accused and that the investigation was conducted fairly and transparently.
- FSL Report Significance: The prosecution emphasized that the FSL report confirmed that the soil on the accused’s shoes matched the soil from the pond where the victim’s body was found, linking the accused to the crime scene.
Submissions Table
| Issue | Appellant’s Submissions | Respondent’s Submissions |
|---|---|---|
| Last Seen Together | Witness testimonies are inconsistent and unreliable; witnesses did not come forward promptly. | Witnesses are credible and their testimonies establish that the accused was the last person seen with the victim. |
| Extra-Judicial Confession | The confession is weak, and the supervisor’s initial statement did not mention it. | The confession is a crucial piece of evidence that corroborates the guilt of the accused. |
| FSL Report | The report is vague and inconclusive; the prosecution failed to establish that the soil was unique to the pond area. | The report confirms that the soil on the accused’s shoes matched the soil from the pond, linking him to the crime scene. |
| Investigation | Flawed and tainted investigation; forensic samples from other watchmen were withheld. | The investigation was conducted fairly and transparently; the Investigating Officers faithfully collected incriminating evidence. |
Issues Framed by the Supreme Court
- Whether the prosecution has proven the chain of incriminating circumstances beyond a reasonable doubt to establish the guilt of the accused.
- Whether the evidence presented regarding the “last seen together” circumstance is reliable and credible.
- Whether the extra-judicial confession allegedly made by the accused is admissible and carries evidentiary value.
- Whether the FSL report linking the soil found on the accused’s shoes to the pond where the victim’s body was found is conclusive and incriminating.
Treatment of the Issue by the Court: “The following table demonstrates as to how the Court decided the issues”
| Issue | Court’s Decision | Brief Reasons |
|---|---|---|
| Whether the prosecution has proven the chain of incriminating circumstances beyond a reasonable doubt. | No | The Court found that the prosecution failed to establish a complete and unbroken chain of incriminating circumstances with reliable evidence. |
| Whether the evidence presented regarding the “last seen together” circumstance is reliable and credible. | No | The Court determined that the testimonies of the witnesses were inconsistent, shaky, and tainted with improvements, making them unworthy of credence. |
| Whether the extra-judicial confession allegedly made by the accused is admissible and carries evidentiary value. | No | The Court found the evidence of the extra-judicial confession unacceptable because the witness did not promptly inform the police, and the testimony was full of contradictions. |
| Whether the FSL report linking the soil found on the accused’s shoes to the pond where the victim’s body was found is conclusive and incriminating. | No | The Court concluded that the FSL report was inconclusive and did not definitively link the accused to the crime, as the soil could have been from other places. |
Authorities
Case Laws and Legal Provisions Relied Upon by the Court
- Sharad Birdhichand Sharda v. State of Maharashtra (1984) 4 SCC 116 [Supreme Court of India]: This case was relied upon to reiterate the principles governing a case based purely on circumstantial evidence. The Court emphasized that the prosecution must prove the entire chain of incriminating circumstances beyond a reasonable doubt.
- Section 293 of the Code of Criminal Procedure (CrPC): The Court noted that there was no evidence to show that the observations made by the expert in the FSL report were admissible ipso facto under this section.
Authority Treatment Table
| Authority | Court | How Treated |
|---|---|---|
| Sharad Birdhichand Sharda v. State of Maharashtra (1984) 4 SCC 116 | Supreme Court of India | Followed |
| Section 293 of the Code of Criminal Procedure (CrPC) | Supreme Court of India | Considered |
Judgment
How each submission made by the Parties was treated by the Court?
| Submission | Party | Court’s Treatment |
|---|---|---|
| Unreliable Last Seen Evidence | Appellant | Accepted. The Court found the testimonies of witnesses to be inconsistent and unreliable. |
| Doubtful Extra-Judicial Confession | Appellant | Accepted. The Court deemed the extra-judicial confession as weak and lacking credibility. |
| Inconclusive FSL Report | Appellant | Accepted. The Court found the FSL report to be vague and inconclusive. |
| Flawed Investigation | Appellant | Accepted. The Court noted significant flaws and lapses in the investigation. |
| Chain of Circumstantial Evidence | Respondent | Rejected. The Court held that the prosecution failed to establish a complete and unbroken chain of incriminating circumstances. |
| Reliable Witnesses | Respondent | Rejected. The Court found the witnesses to be unreliable and their testimonies inconsistent. |
| FSL Report Significance | Respondent | Rejected. The Court deemed the FSL report as inconclusive and not definitively linking the accused to the crime. |
How each authority was viewed by the Court?
- Sharad Birdhichand Sharda v. State of Maharashtra [CITATION]: The Court followed the principles laid down in this case, emphasizing that the prosecution must prove the entire chain of incriminating circumstances beyond a reasonable doubt.
What weighed in the mind of the Court?
The Supreme Court’s decision to acquit the accused was primarily influenced by the following factors:
- Flawed Investigation: The Court heavily emphasized the “shabby and perfunctory investigation” as a critical factor. The lack of thoroughness and the failure to properly examine key witnesses undermined the prosecution’s case.
- Unreliable Evidence: The Court found that the evidence presented by the prosecution, including the testimonies of witnesses and the FSL report, was unreliable and inconsistent.
- Incomplete Chain of Circumstances: The Court determined that the prosecution failed to establish a complete and unbroken chain of incriminating circumstances, which is essential for a conviction based on circumstantial evidence.
Ranking of Sentiment Analysis of Reasons
| Reason | Percentage |
|---|---|
| Flawed Investigation | 40% |
| Unreliable Evidence | 35% |
| Incomplete Chain of Circumstances | 25% |
Fact:Law
| Category | Percentage |
|---|---|
| Fact (Consideration of factual aspects of the case) | 60% |
| Law (Consideration of legal aspects of the case) | 40% |
The court’s decision was more influenced by the factual aspects of the case, particularly the inconsistencies and flaws in the evidence and investigation, than by purely legal considerations.
Logical Reasoning
Key Takeaways
- Importance of Thorough Investigations: This case underscores the critical importance of thorough and unbiased investigations in ensuring justice. Flawed investigations can lead to wrongful convictions.
- Reliability of Evidence: The judgment emphasizes the need for reliable and consistent evidence. Courts must carefully scrutinize the credibility of witnesses and the conclusiveness of scientific reports.
- Burden of Proof: The prosecution bears the burden of proving the guilt of the accused beyond a reasonable doubt. This includes establishing a complete and unbroken chain of incriminating circumstances.
- Protection of Rights: The judgment reaffirms the importance of protecting the rights of the accused and ensuring that convictions are based on solid evidence, not mere suspicion or conjecture.
Development of Law
The ratio decidendi of this case is that a conviction based on circumstantial evidence requires a complete and unbroken chain of incriminating circumstances proven beyond a reasonable doubt. The judgment reinforces the principle that flawed investigations and unreliable evidence cannot sustain a conviction, especially in cases involving serious crimes.
Conclusion
In Ramkirat Munilal Goud vs. State of Maharashtra, the Supreme Court overturned the conviction of the accused due to a flawed investigation and unreliable evidence. The Court emphasized the importance of thorough investigations, reliable evidence, and the need to prove guilt beyond a reasonable doubt. This judgment serves as a reminder of the critical role of the justice system in protecting the rights of the accused and ensuring that convictions are based on solid evidence.