Conviction Based Solely on Circumstantial Evidence Quashed as Chain of Events Fails to Exclude Reasonable Doubt

A bench of Justices Pankaj Mithal and Ahsanuddin Amanullah heard the appeal against conviction under Section 302 IPC arising from the murder of Ramlal, wherein the appellant, Hansraj, challenged the confirmation of his life sentence by the High Court. The appeal proceeded after this Court condoned delay in filing the Special Leave Petition and had earlier directed that the appellant, who had been in custody for over ten years, be released on bail.

The Supreme Court allowed the appeal, set aside the conviction and sentence, and acquitted the appellant on the ground that the circumstantial case against him did not exclude every reasonable hypothesis of innocence. The Court held that the “chain of events” was not complete and there were material lacunae in the prosecution case — including contradictions in witness statements, doubtful “last seen” evidence, unreliable recovery of the alleged weapon and absence of forensic linkage. The Court, in its reasoning, observed: “the circumstances from which the conclusion of guilt is to be drawn should be fully established... the facts established should be consistent with the hypothesis of the guilt of the accused... the circumstance should exclude every other possible hypothesis except the one to be proved... and there must be a chain of evidence so complete as not to leave any reasonable ground for a conclusion consistent with the innocence of the accused.” The Court further noted that “the appellant cannot be held guilty of the commission of the offence beyond reasonable doubt and therefore, in such circumstances the benefit of doubt goes in his favour.”

Background The murder occurred on 28.03.2002 at the deceased’s house in village Ghotha Sakulpara, Bhanupratappur. The prosecution case was entirely circumstantial. It was alleged that the appellant, who had been working for the deceased for about two months, left home at about 7:00 am on his cycle and returned around 9:00 am saying his tyre had been punctured. The deceased’s wife, Budhiyarin Bai (PW-5), left to sell paddy and on returning at about 9:30 am found her husband on the floor with his neck severed and raised an alarm. She later purportedly saw the appellant fleeing with a farsi (a farming implement) in his hand. Neighbours reached the spot; an FIR was lodged at 11:15 am the same day.

The trial court convicted and sentenced the appellant to life imprisonment on 19.12.2002; the High Court confirmed the conviction on 30.07.2010. The Supreme Court granted leave to appeal after condoning a delay of 653 days and released the appellant on bail given his prolonged incarceration.

On appeal, the Court scrutinised the circumstantial chain. It observed the alleged motive — disputes over wages — was trivial and not supported by material evidence. The “last seen” evidence was inconsistent: witnesses differed on whether they actually saw the appellant fleeing and on his identity. The farsi said to be the weapon was recovered 20–25 days after the incident on the appellant’s alleged pointing out; while it bore blood stains, no forensic test was produced to link the blood to the deceased. Clothes said to have stains were produced by a hostile witness and similarly lacked forensic corroboration. The police did not investigate whether the appellant’s cycle tyre was actually punctured, which would have corroborated his return. Applying the five-fold principles governing circumstantial proof from Sharad Birdhichand Sarda v. State of Maharashtra, the Court found that the circumstances were not of “a conclusive nature” and did not exclude every reasonable hypothesis of innocence.

The Court set aside the judgments of the trial court and High Court, acquitted the appellant, discharged his sureties and bail bonds and observed that he had already undergone more than ten years’ incarceration. The appeal was allowed.

Case Details: Case No.: 2025 INSC 178; Criminal Appeal No. 1387 of 2012 Case Title: Hansraj v. State of Chhattisgarh Appearances: For the Petitioner(s): Not indicated in the judgment For the Respondent(s): Not indicated in the judgment