Conviction Set Aside Where Circumstantial Case Left Room For Two Reasonable Views; Accused Ordered Released

A Bench of Justices Pankaj Mithal and Ahsanuddin Amanullah heard an appeal against the conviction of a man for the murder of his first wife, arising from an SLP (Crl.) before this Court. The challenge questioned whether the prosecution had established guilt beyond reasonable doubt on the basis of circumstantial evidence and whether the trial and High Court rightly relied on hostile witnesses and medical opinion to convict.

The Court allowed the appeal, set aside the conviction and ordered the immediate release of the appellant. The Bench held that the prosecution failed to establish a complete chain of circumstances pointing exclusively to the accused and that the evidence gave "ample leverage for two conflicting opinions." The Court relied upon the established panchsheel of circumstantial evidence and emphasised that the initial burden remained on the prosecution. The Court, in its reasoning, observed: "In view of the totality of the facts and circumstances of this case, we are of the opinion that the prosecution has completely failed to produce evidence to prove the guilt of the appellant beyond the shadow of doubt on the basis of the circumstantial evidence. Rather the evidence on record gives ample leverage for two conflicting opinions, and in such circumstances, the benefit of doubt has to be given in favour of the appellant." The judgment also recalled the "panchsheels of circumstantial evidence" and reiterated that Section 106 of the Evidence Act could be invoked only after the prosecution had prima facie discharged its burden.

Background

The appellant, Ravi, had been convicted by trial and the High Court for the death of his first wife, Jamni, allegedly strangled on 22 August 2014. The prosecution case rested largely on circumstantial material and on statements in a Zero FIR lodged by the deceased's brother, who later turned hostile and disowned the contents of the FIR. Two other close relatives also recanted and were declared hostile. The police recovered a rope on the appellant's disclosure; the investigating officer conceded that similar ropes were readily available in the market. The post-mortem surgeon opined death due to asphyxia caused by hanging with ligature marks on the neck but accepted in cross‑examination that chronic tuberculosis could cause death by asphyxia and that ligature marks might have resulted from the long journey the body underwent.

The Court analysed the evidence against the five principles laid down in Sharad Birdhichand Sarda v. State of Maharashtra, observing that the circumstances were not wholly inconsistent with any hypothesis other than the appellant's guilt and did not constitute a conclusive chain. The Bench considered the prosecution’s reliance on Section 106 of the Evidence Act but held that the provision could not be used to remedy the prosecution's failure to establish the essential elements of the offence. The Court noted the appellant's statement under Section 313 CrPC that the deceased suffered from chronic tuberculosis and had been under treatment; it observed that the prosecution failed to re‑examine medical witnesses or produce independent evidence to rebut that claim. In light of these infirmities, the Court concluded that the benefit of doubt must be given to the appellant, allowed the appeal, set aside the impugned High Court order dated 23.01.2019 and directed immediate release. The Court recorded that the appellant had been in custody for over ten years and accordingly ordered his release. The Bench also recorded appreciation for the legal aid counsel Ms. Sonia Mathur, Senior Advocate, assisted by Ms. Surbhi Bhardwaj.

Case Details: Case No.: 2025 INSC 170 Case Title: Ravi v. The State of Punjab Appearances: For the Petitioner(s): Ms. Sonia Mathur, Senior Advocate; Ms. Surbhi Bhardwaj, Advocate For the Respondent(s): Not indicated in the judgment record