Supreme Court Held – Failure to Establish Guilt Beyond Reasonable Doubt – Chain of Circumstantial Evidence Incomplete – Appellant Acquitted (Para 16, 17, 18)

Circumstantial evidence did not establish guilt beyond reasonable doubt. The last seen theory was not conclusively proven. The recovery of the alleged weapon of crime was doubtful and lacked forensic corroboration. The benefit of doubt must go to the accused, leading to acquittal.

The conviction was set aside, and the appellant was acquitted. The appeal was allowed, and the appellant was released from all charges.

Acts and Sections Discussed:

• Indian Penal Code, 1860 (IPC) – Section 302 – Murder – Life Imprisonment – Benefit of Doubt – Acquittal
• Code of Criminal Procedure, 1973 (CrPC) – Appeal – Special Leave Petition – Delay Condonation

Subjects:

Murder Conviction – Circumstantial Evidence – Last Seen Theory – Recovery of Weapon – Motive Not Established – Benefit of Doubt – Acquittal

Facts:

a. Nature of the Litigation: Criminal appeal against conviction under Section 302 of the Indian Penal Code, 1860.
b. Who Asked the Court and for What Remedy? Appellant sought acquittal, contending that the case was based solely on circumstantial evidence, which was not conclusively proven.
c. Reason for Filing the Case: The appellant challenged the conviction on the grounds of weak circumstantial evidence, unreliable last seen theory, and doubtful recovery of the weapon.
d. What Had Already Been Decided Until Now? The Trial Court convicted the appellant, sentencing him to life imprisonment, which was upheld by the High Court.

Issues:

1. Whether the circumstantial evidence established the guilt of the appellant beyond a reasonable doubt?
2. Whether the "last seen" theory and the alleged motive were sufficient to sustain the conviction?
3. Whether the recovery of the weapon and blood-stained clothes was reliable and legally admissible?

Submissions/Arguments:

• Appellant’s Argument:
  a. Circumstantial evidence was not conclusive – no eyewitness to the crime.
  b. Last seen theory was unreliable – no corroboration of the appellant’s return to the crime scene.
  c. Motive was not strong enough to establish intention to murder.
  d. Recovery of the weapon was doubtful – no forensic report confirming blood match.

• Prosecution’s Argument:
  a. The appellant was the last person seen with the deceased before the murder.
  b. Recovery of the weapon (farsi) and blood-stained clothes pointed to his guilt.
  c. The motive was clear – non-payment or delay in payment of wages.

Ratio Decidendi:

• In a case based on circumstantial evidence, the prosecution must establish a complete chain of events leading to the guilt of the accused.
• The mere presence of motive is insufficient unless supported by conclusive evidence.
• Last seen theory and recovery of weapon must be corroborated with independent evidence for a conviction.