Acquittal in Kidnapping and Murder Case: Supreme Court Highlights Gaps in Circumstantial Evidence

The case of Baiju Kumar Soni & Anr. vs. State of Jharkhand revolves around the conviction and subsequent acquittal of two individuals accused of kidnapping and murdering a minor girl. The Supreme Court’s ruling in this case underscores the importance of proving guilt beyond reasonable doubt, especially in cases based on circumstantial evidence.

The core issue in the case was whether the prosecution had sufficiently established a chain of evidence linking the accused to the crime. The Supreme Court ultimately ruled that the evidence presented was inadequate to uphold the conviction, granting the accused the benefit of the doubt.

Background of the Case

The case pertained to the disappearance and murder of a 3.5-year-old girl in Jharkhand. On January 8, 2006, the child went missing while playing outside her house. Her father, PW10, initially searched for her before lodging an official complaint on January 9, 2006, at the Bhurkunda Police Station. This led to the registration of an FIR on January 13, 2006, under Sections 364 and 365 of the Indian Penal Code (IPC).

On January 11, 2006, PW10 received a threatening call stating that his daughter would be returned in the evening and warning him against informing the police. The following day, his brother, PW4, received another call claiming the child had been kidnapped. The caller directed them to the roof of a nearby temple, where they found the girl’s red top, slippers, and a threatening letter.

The child’s dead body was later discovered on January 18, 2006, in a black rexin bag near a dam. A post-mortem report indicated that she had been strangled and had died between three to seven days before the body was found. Subsequently, Sections 302 and 201 IPC were added to the charges.

Prosecution’s Case

The prosecution presented the following evidence:

• PW10 and PW4 testified about the threatening calls they received, although they could not identify the caller.
• PW7, who operated an STD booth, testified that two calls were made from his booth on January 12, 2006, to specific mobile numbers, and he identified the accused as the individuals who made the calls.
• PW5 stated that he saw the accused carrying a stuffed rexin bag while boarding a train on January 9, 2006. The prosecution linked this to the bag in which the child’s body was found.
• A scarf belonging to the victim was recovered from the house of one of the accused.
• A drawing book, allegedly used to write the threatening letter, was recovered from the house of another accused.

Trial Court’s Verdict

The Trial Court convicted the accused under Sections 364-A (kidnapping for ransom), 302 (murder), and 201 (causing disappearance of evidence) read with Section 34 IPC. They were sentenced to life imprisonment.

High Court’s Decision

The accused appealed to the High Court of Jharkhand, which upheld the conviction, citing the recovery of the victim’s scarf, the drawing book, and the witness testimony regarding the rexin bag as sufficient evidence of guilt.

Supreme Court’s Observations

The Supreme Court critically examined the circumstantial evidence and found several gaps in the prosecution’s case:

• Call Records and Identification Issues: The court noted that while PW7 confirmed that the accused made calls from his booth, there was no evidence linking these calls to the victim’s family.
• No Forensic Analysis of Handwriting: The prosecution failed to prove that the threatening letter was written by the accused. No handwriting expert was consulted.
• Inconsistency in Timeline: The prosecution claimed that the accused carried the child’s body in a bag on January 9, 2006, but the post-mortem suggested she died between January 11 and 15, 2006. This created a discrepancy in the alleged timeline of events.
• Lack of Direct Evidence: There were no eyewitnesses to the actual crime, and the evidence relied upon was circumstantial and inconclusive.

Key Ruling and Verdict

The Supreme Court reaffirmed the principle that circumstantial evidence must form a complete chain leading to only one conclusion: the guilt of the accused. The Court cited Sharad Birdhichand Sarda v. State of Maharashtra and Nizam v. State of Rajasthan, emphasizing that:

“The circumstances from which an inference as to the guilt of the accused is drawn have to be proved beyond reasonable doubt and have to be shown to be closely connected with the principal fact sought to be inferred from those circumstances.”

The Court ruled that the prosecution had failed to meet this burden of proof, granting the accused the benefit of the doubt. The conviction was overturned, and the accused were acquitted.

Implications of the Judgment

This judgment serves as a critical reminder of the stringent requirements for proving guilt in cases based on circumstantial evidence. It highlights:

• The necessity of forensic evidence to corroborate claims, especially when relying on handwriting analysis or call records.
• The importance of ensuring that all circumstantial evidence aligns logically and temporally with the alleged crime.
• The principle that any reasonable doubt must favor the accused.

The Supreme Court’s ruling reinforces that while circumstantial evidence can be used to convict, it must be airtight and lead to no other reasonable conclusion but the guilt of the accused. This case will likely influence future criminal trials, ensuring that courts require a higher standard of proof before convicting individuals solely based on circumstantial evidence.

Petitioner Name: Baiju Kumar Soni & Anr..
Respondent Name: State of Jharkhand.
Judgment By: Justice Uday Umesh Lalit, Justice Vineet Saran.
Place Of Incident: Jharkhand.
Judgment Date: 01-08-2019.

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