An appeal against the convictions under Sections 302, 120B, and 201 of the Indian Penal Code (IPC), related to the murder of Dharmendra Satnami. The Supreme Court set aside the High Court's judgment, acquitting the accused due to the failure of the prosecution to establish a chain of evidence beyond reasonable doubt.

1. Case Background

• Missing Person Report: On 2nd December 2011, Ramavtar (PW-1) lodged a missing person report for his son, Dharmendra Satnami.
• Accused's Confession: During police interrogation, the accused confessed to strangling Dharmendra to death and disposing of the body in a pond.
• Memorandum Statements: The police recorded the accused’s statements on 3rd and 6th December 2011, leading to the recovery of the body.
• FIR: A First Information Report (FIR) was registered for the offences committed between 30th November and 3rd December 2011.

2. Prosecution’s Case

The prosecution relied on the accused's memorandum statements, arguing that Dinesh Chandrakar (accused No. 3) had conspired with the other accused to murder Dharmendra for ₹90,000. The deceased was lured and strangled by the accused, who then disposed of the body in a pond. The charge sheet was filed, and the accused were tried for murder, conspiracy, and destruction of evidence.

3. Trial and Conviction

• Trial Court: Found the accused guilty under Sections 302 (Murder), 120B (Criminal Conspiracy), and 201 (Destruction of Evidence) IPC.
• High Court: Upheld the convictions.

4. Supreme Court’s Findings

• Failure of Chain of Circumstantial Evidence: The Supreme Court found that the prosecution failed to prove the discovery of the dead body based on the accused’s statements under Section 27 of the Evidence Act.
• Flawed Witness Testimony: Key witnesses admitted that they were informed of the crime before the accused's confessions were recorded, undermining the prosecution's case.
• Acquittal: The Supreme Court acquitted all accused, noting the prosecution’s failure to prove guilt beyond a reasonable doubt.

Acts and Sections Discussed

• Section 302 IPC – Punishment for Murder
• Section 120B IPC – Criminal Conspiracy
• Section 201 IPC – Causing Disappearance of Evidence
• Section 27, Indian Evidence Act – Confession leading to discovery

Ratio Decidendi

The Supreme Court emphasized the principle that circumstantial evidence must form an unbroken chain leading only to the guilt of the accused. In this case, the prosecution's reliance on memorandum statements under Section 27 of the Evidence Act failed, as the discovery of the dead body was known before the accused's statements. Thus, the convictions could not be upheld based on suspicion or incomplete evidence.

Subject

Acquittal due to failure to prove circumstantial evidence in a murder case.

Criminal Law, Murder, Acquittal, Indian Penal Code, Evidence Act, Supreme Court Judgment, Circumstantial Evidence.