Supreme Court Acquits Chandrabhan Sudam Sanap in Mumbai Murder Case Citing Gaps in Evidence

The Supreme Court of India, in a crucial ruling, has acquitted Chandrabhan Sudam Sanap, overturning the Bombay High Court’s decision that upheld his conviction and death sentence. The case, based on circumstantial evidence, involved the brutal murder of a 23-year-old woman, EA, whose body was discovered in Mumbai in January 2014. The Supreme Court found significant gaps in the prosecution’s case, leading to the acquittal of the accused.

Background of the Case

The case revolved around the murder of EA, a young woman who had been working in Mumbai and staying at the YWCA Hostel in Andheri. On January 4, 2014, she boarded the Visakhapatnam-LTT Express to return to Mumbai after visiting her parents in Andhra Pradesh. She last contacted her father at 9:00 PM on January 4, 2014, from Solapur. Upon reaching Mumbai, she never contacted her family, prompting her father to file a missing person’s report.

Days later, on January 16, 2014, her decomposed body was found in the bushes near the Eastern Express Highway, with evidence of burns and blunt force injuries. A case was registered, and the police began their investigation.

Charges and Trial Court Verdict

Chandrabhan Sudam Sanap was arrested on March 2, 2014, and was charged under multiple sections of the Indian Penal Code (IPC), including:

Section 302 (Murder)
Section 364 (Kidnapping)
Section 366 (Kidnapping a woman to compel her for marriage or illicit intercourse)
Section 376(2)(m) (Aggravated rape)
Section 376A (Rape causing death)
Section 392 read with 397 (Robbery with attempt to cause death or grievous hurt)
Section 201 (Causing disappearance of evidence of offense)

The Sessions Court found Sanap guilty and sentenced him to death. The Bombay High Court upheld the conviction and confirmed the death penalty in 2018.

Arguments by the Defense

The defense counsel, appearing pro bono, challenged the conviction on multiple grounds:

The prosecution’s case was based entirely on circumstantial evidence without any direct proof linking Sanap to the crime.
The CCTV footage allegedly showing Sanap with the victim was not supported by a valid Section 65-B(4) certificate under the Indian Evidence Act, making it inadmissible.
Key prosecution witnesses, including last-seen witnesses and forensic experts, gave contradictory statements.
The extra-judicial confession given to a witness, PW-9, was unreliable.
The recovery of the victim’s belongings, including a trolley bag, lacked credibility.

Prosecution’s Stand

The prosecution argued that:

The victim was last seen with Sanap at the railway station, establishing his involvement.
CCTV footage from Lokmanya Tilak Terminus (LTT) showed the accused and victim together.
Forensic evidence suggested the victim was raped and murdered.
Sanap’s confession to PW-9 was credible.
The recovery of victim’s belongings from his sister’s house and a woman in Nashik supported the case.

Supreme Court’s Analysis and Judgment

1. Flaws in CCTV Evidence

The Court observed that the CCTV footage from the railway station was a crucial piece of evidence, yet the prosecution failed to provide a mandatory certificate under Section 65-B(4) of the Indian Evidence Act. Without this certification, the footage was inadmissible.

“In view of the settled law in Arjun Panditrao Khotkar vs. Kailash Kushanrao Gorantyal (2020), we cannot rely on the CCTV footage in the absence of a valid Section 65-B certificate.”

2. Issues with Last Seen Witnesses

The last seen theory was based on the testimony of PW-20 and PW-21, who claimed to have seen the accused with the victim. However, the Court found these statements unreliable due to inconsistencies and delays in recording them.

3. Unreliability of Extra-Judicial Confession

The alleged confession made by the accused to PW-9 lacked credibility. The Court noted that PW-9 had been in police custody, and his testimony appeared coached.

“Extra-judicial confessions must be approached with caution and require corroboration. In this case, the confession is not trustworthy.”

4. Gaps in Recovery of Evidence

The prosecution claimed that Sanap had disposed of the victim’s trolley bag in Nashik, which was later recovered from a woman. However, the witness admitted she was pressured by the police, weakening this evidence.

5. Failure to Prove Chain of Circumstances

The Court emphasized that in cases based on circumstantial evidence, all links in the chain must be conclusively established. In this case, there were too many gaps, including:

No direct evidence of abduction or murder.
Failure to prove that the accused and victim traveled together beyond the railway station.
Uncertainty regarding the exact time of death.
Contradictions in forensic findings.

Final Verdict

The Supreme Court ruled:

“The prosecution has failed to prove the case beyond a reasonable doubt. The circumstantial evidence does not conclusively establish the guilt of the accused. Consequently, the conviction and sentence of the appellant are set aside.”

Sanap was acquitted of all charges and ordered to be released immediately unless required in another case.

Conclusion

This judgment underscores the importance of strict adherence to evidentiary laws in criminal cases. The ruling highlights the necessity for courts to rely on robust, legally admissible evidence rather than speculation or procedural shortcuts. The case serves as a reminder that the burden of proof in criminal trials must be met fully, ensuring that justice prevails.

Petitioner Name: Chandrabhan Sudam Sanap.
Respondent Name: State of Maharashtra.
Judgment By: Justice B.R. Gavai, Justice Prashant Kumar Mishra, Justice K.V. Viswanathan.
Place Of Incident: Mumbai, Maharashtra.
Judgment Date: 28-01-2025.

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