Supreme Court Acquits Convicts in Murder Case Due to Lack of Conclusive Circumstantial Evidence

The Supreme Court of India, in Suresh Chandra Tiwari & Anr. v. State of Uttarakhand, overturned the convictions of two individuals accused of murder, ruling that the prosecution failed to establish a conclusive chain of circumstantial evidence. The Court found multiple inconsistencies in the case, leading to the acquittal of the accused.

Background of the Case

The case stemmed from an incident on February 3, 1997, when the dead body of the victim was discovered in front of a shop in Lohaghat, Uttarakhand. An FIR was registered, and an investigation led to the arrest of Suresh Chandra Tiwari and Bhuwan Chandra Punetha. They were charged under Sections 302 and 201 of the Indian Penal Code (IPC) for murder and causing the disappearance of evidence.

The prosecution case was based entirely on circumstantial evidence, as there were no direct eyewitnesses to the alleged crime.

Trial Court’s Findings

• The trial court convicted the accused under Section 302 read with Section 34 IPC and sentenced them to life imprisonment.
• The court relied on circumstantial evidence, including the last-seen theory and the discovery of blood-stained stones near the crime scene.

High Court’s Findings

• The Uttarakhand High Court modified the conviction from Section 302 IPC (murder) to Section 304 Part I IPC (culpable homicide not amounting to murder), reducing the sentence to seven years of rigorous imprisonment.
• The High Court observed that the fatal injury could have resulted from a single blow rather than a premeditated act.

Key Legal Issues Considered

• Whether the circumstantial evidence presented by the prosecution was sufficient to prove the guilt of the accused beyond a reasonable doubt.
• Whether the accused were last seen with the deceased close enough to the time of death to rule out any other possibility.
• Whether the discovery of the alleged murder weapon (a blood-stained stone) could be linked to the crime.
• Whether the High Court was justified in altering the conviction from murder to culpable homicide.

Arguments of the Appellants (Accused)

• The last-seen theory was weak, as there was a significant time gap between when the deceased was allegedly last seen with the accused and when the body was discovered.
• The recovery of a blood-stained stone was inconclusive, as forensic reports failed to link the blood to the deceased.
• There was no direct evidence, and the chain of circumstantial evidence was incomplete.
• The accused had no motive strong enough to commit murder.

Arguments of the Respondent (State of Uttarakhand)

• The accused were last seen with the deceased a few hours before his death.
• They were found walking near the crime scene at an unusual hour.
• The prosecution’s chain of events led to the logical conclusion that the accused were guilty.
• The High Court had already considered mitigating circumstances by reducing the sentence.

Supreme Court’s Observations

On the Standard of Circumstantial Evidence

The Court reaffirmed the five principles governing circumstantial evidence as laid down in Sharad Birdhichand Sarda v. State of Maharashtra (1984). It held that:

“The circumstances must be fully established and form a complete chain that rules out all hypotheses except that of the guilt of the accused.”

On the Last-Seen Theory

The Court found that the prosecution failed to establish proximity between the time the deceased was last seen with the accused and the time of death. It ruled:

“The last-seen circumstance alone cannot sustain conviction unless it is corroborated by other credible evidence.”

On the Recovery of Blood-Stained Stone

The forensic report did not conclusively link the blood on the stone to the deceased. The Court observed:

“Without clear forensic linkage, the recovery of a weapon or blood-stained object cannot be a decisive factor in proving guilt.”

On the High Court’s Reduction of Sentence

The Supreme Court criticized the High Court’s decision to reduce the sentence, stating:

“If the evidence does not establish guilt beyond a reasonable doubt, conviction under any section is unjustified.”

Final Judgment

The Supreme Court allowed the appeal and acquitted the accused. It held:

• The prosecution failed to establish a complete chain of evidence linking the accused to the crime.
• The recovery of evidence was unreliable and could not be directly linked to the crime.
• The High Court erred in modifying the conviction instead of acquitting the accused outright.

Implications of the Judgment

• Reaffirms the strict evidentiary standards required in cases based on circumstantial evidence.
• Limits the use of the last-seen theory in the absence of corroborating evidence.
• Emphasizes that forensic evidence must conclusively link an accused to a crime.
• Reiterates that a conviction must be based on certainty, not probability.

The Supreme Court’s ruling underscores the importance of due process and the necessity of a high threshold of proof in criminal cases based on circumstantial evidence.

Petitioner Name: Suresh Chandra Tiwari & Anr..
Respondent Name: State of Uttarakhand.
Judgment By: Justice J.B. Pardiwala, Justice Manoj Misra.
Place Of Incident: Lohaghat, Uttarakhand.
Judgment Date: 27-11-2024.

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