Supreme Court Acquits Accused in Circumstantial Evidence Murder Case

The case of Umesh Tukaram Padwal & Anr. v. State of Maharashtra centered on the conviction of the accused under Sections 364, 302 read with 34 of the Indian Penal Code (IPC) for kidnapping and murdering the deceased, Dnyaneshwar, and under Section 420 IPC for cheating him out of Rs. 45,000. The Supreme Court ultimately overturned their conviction due to lack of conclusive evidence.

The case highlights the importance of proving guilt beyond reasonable doubt in cases based on circumstantial evidence. The prosecution’s inability to establish a clear link between the accused and the alleged murder led to the acquittal of the appellants.

Background and Key Issues

The case began when the deceased’s uncle, PW-1, approached the first accused (A1), Umesh Padwal, to arrange a job for Dnyaneshwar at the Jindal Plant in Vasind. A1 demanded Rs. 60,000 for the arrangement. On July 7, 2002, PW-1 paid Rs. 10,000 to A1, and on July 11, 2002, the deceased handed over the remaining Rs. 35,000 to A1 in the presence of the second accused (A2), Pravin Godse.

Following the transaction, A1 and A2 left with the deceased for the Jindal Plant, instructing PW-1 not to accompany them. The deceased did not return that evening, prompting PW-1 to visit A1’s house, where he found that A1 was also absent. When the deceased remained untraceable, PW-1 lodged a police complaint on July 13, 2002.

The deceased’s body was later recovered from a valley at Goraksha Gad, leading to the arrest of the accused and their subsequent conviction by the trial court.

Prosecution’s Arguments

The prosecution relied on three key pieces of circumstantial evidence:

• The accused had a financial motive for the crime, as they had taken Rs. 45,000 from the deceased.
• The deceased was last seen alive in the company of the accused.
• The accused led the police to the discovery of the deceased’s body and other incriminating items.

Based on these factors, the trial court convicted A1 under Section 420 IPC and both A1 and A2 under Sections 364 and 302 read with 34 IPC.

Defense Arguments

The accused contended that:

• They had no motive to kill the deceased.
• The “last seen” theory was weak since the deceased allegedly disappeared from Vasind Railway Station, as reported by A1 to PW-1 on the same day.
• There was no direct evidence linking them to the murder.
• The prosecution’s claim that the accused led them to the dead body was unreliable.

Supreme Court’s Observations

The Supreme Court thoroughly examined the evidence and found that the prosecution failed to establish the accused’s guilt beyond reasonable doubt. The Court made the following key observations:

1. Failure to Prove Cheating (Section 420 IPC)

“There is no evidence to show that Accused No. 1 had any intention to not arrange a job for the deceased as promised.”

The Court held that A1’s demand for money in exchange for a job did not automatically constitute cheating. The prosecution did not provide proof that A1 never intended to fulfill his promise.

2. Weakness of the ‘Last Seen’ Theory

The Court rejected the ‘last seen’ theory due to inconsistencies in the prosecution’s case:

• A1 informed PW-1 on the night of July 11, 2002, that the deceased disappeared from Vasind Railway Station.
• The accused did not abscond after the deceased went missing.
• The hotel register at Goraksha Gad, where the accused and deceased allegedly stayed, was unreliable due to lack of handwriting verification.

“The material on record indicates that the accused did not have knowledge of the whereabouts of the deceased after his disappearance.”

3. Unreliable Recovery of the Dead Body

The Supreme Court raised serious doubts about the claim that A1 led the police to the body. The evidence showed:

• PW-4, a prosecution witness, contradicted the prosecution’s claim that A1 voluntarily disclosed the body’s location.
• The body was found in a highly decomposed state, making identification difficult.
• The cause of death could not be confirmed, as the post-mortem report did not establish strangulation.

“The prosecution has made a botched attempt to improve its case regarding the recovery of the dead body from time to time.”

4. Lack of a Complete Chain of Circumstantial Evidence

For a conviction based on circumstantial evidence, all circumstances must form a complete chain that leaves no doubt about the accused’s guilt. The Court found that:

• The prosecution failed to establish motive convincingly.
• The ‘last seen’ evidence did not conclusively place the accused with the deceased at the time of death.
• The body’s recovery was not linked to the accused beyond reasonable doubt.

“In our considered opinion, the benefit of doubt should therefore be granted in their favor.”

Final Judgment

The Supreme Court set aside the judgments of the trial court and the High Court, acquitting both accused of all charges:

• A1 was acquitted of cheating under Section 420 IPC.
• A1 and A2 were acquitted of abduction and murder under Sections 364 and 302 read with 34 IPC.
• The Court discharged their bail bonds and declared them free of all charges.

Impact of the Judgment

The Supreme Court’s ruling underscores the importance of:

• Ensuring a complete chain of circumstantial evidence before convicting an accused.
• Not relying on weak ‘last seen’ evidence without corroboration.
• Conducting proper forensic analysis and verifying cause of death in murder cases.
• Preventing manipulation of evidence by law enforcement agencies.

This judgment serves as a crucial precedent for criminal cases relying solely on circumstantial evidence. It reinforces the principle that an accused person cannot be convicted unless their guilt is proved beyond a reasonable doubt.

Petitioner Name: Umesh Tukaram Padwal & Anr..
Respondent Name: State of Maharashtra.
Judgment By: Justice N.V. Ramana, Justice Mohan M. Shantanagoudar, Justice Ajay Rastogi.
Place Of Incident: Maharashtra.
Judgment Date: 03-09-2019.

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