Jahanvi Agarwal
Recently, the Supreme Court of India highlighted an issue while acquitting a defendant in a 22-year-old murder case. The chain of evidence in a case of circumstantial evidence must be complete in all respects and also exclude any other possibility.
The Division Bench of Justice Vikram Nath and Justice Ahsanuddin Amanullah held that the case against the defendants will collapse if there are any missing or untested links in the chain of circumstantial evidence.
The Bench stated that:
“In a case of circumstantial evidence, the chain has to be complete in all respects so as to indicate the guilt of the accused and also exclude any other theory of the crime. The law is well settled on the above point,”
In 2010, the Madhya Pradesh High Court affirmed the appellant’s conviction under Section 302 of the Indian Penal Code (IPC), which deals with murder. The court made the statement while permitting an appeal against that judgment.
In the instant case, the police utilized the appellant’s purpose, where he was last seen, and the discovery of an assault weapon as circumstantial evidence against the accused.
The High Court decided that the evidence supporting these two connections—motive and last seen—was solid. However, it was determined that the third connection—the discovery of a weapon from the appellant—was either unsubstantiated or invalid.
The High Court also upheld the appellant’s murder conviction. In a subsequent appeal, the Supreme Court determined that the High Court erred by taking this stance.
Supreme Court observed that the reliance was made on Sharad Birdichand Sharda v. State of Maharashtra (1984) and Sailendra Rajdev Pasvan v. State of Gujarat (2020).
As a result, the Supreme Court overturned the appellant’s conviction and permitted his appeal and stated that:
“If the High Court found one of the links to be missing and not proved in view of the settled law on the point, the conviction ought to have been interfered with.”
Case Name: Laxman Prasad @ Laxman v. State of Madhya Pradesh.
Diary Number: 821/2012
Bench: Justice Vikram Nath and Justice Ahsanuddin Amanullah