Indian Penal Code, 1860, Section 201, 302 – Murder – Circumstantial Evidence – Conviction set aside – The prosecution’s case relied on circumstantial evidence, including the recovery of a knife, last seen together, medical opinion on the cause of death, and the deceased’s habit of drinking with the appellant.
The Court analyzed the evidence and submissions presented. It noted that while the circumstances suggested suspicion, they failed to meet the stringent criteria outlined in Sharad Birdhichand Sarda v. State of Maharashtra [(1984) 4 SCC 116] for establishing guilt beyond a reasonable doubt based on circumstantial evidence. The recovery of the weapon at the appellant’s instance was not adequately proved, weakening a crucial link in the chain of circumstances. Additionally, evidence suggesting alternative explanations, such as the possibility of the deceased’s injury being caused by a motorcycle accident, raised doubts about the prosecution’s narrative.
Considering these factors, the Court concluded that the prosecution had not conclusively established the appellant’s guilt. The circumstances were not consistent solely with the hypothesis of the appellant’s guilt, and there were reasonable doubts regarding the prosecution’s case. Consequently, the Court allowed the appeal, set aside the impugned judgments, and acquitted the appellant of all charges. (Para 12, 13)
SUPREME COURT OF INDIA
[2024 STPL(Web) 252 SC = 2024 INSC 298]
Arun Shankar Vs. State Of Madhya Pradesh
Criminal Appeal No. 1186 of 2022-Decided on 10-4-2024
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