Supreme Court Acquits Man in Elderly Woman’s Rape and Murder, Cites Gaps in Circumstantial Case

A bench of Justices Dipankar Datta and Augustine George Masih heard the appeal against convictions under Sections 302, 449, 376 and 394 IPC and considered whether the prosecution had proved the appellant’s guilt in a case founded on circumstantial evidence. The appeal arose from the conviction and life sentence imposed by the Sessions Court, upheld by the Madras High Court, in the death, sexual assault and robbery of an 85‑year‑old woman in Coimbatore.

The Supreme Court allowed the appeal, set aside the concurrent convictions and ordered the appellant’s acquittal and immediate release if not required in any other case. The Court held that the prosecution had not established a complete and unbroken chain of circumstantial evidence pointing only to the appellant as the offender and therefore the benefit of doubt must be given to him. The Court, in its reasoning, observed: "Thus, these basic established principles can be summarised in the following terms that the chain of events needs to be so established that the court has no option but to come to one and only one conclusion i.e. the guilt of the accused person. If an iota of doubt creeps in at any stage in the sequence of events, the benefit thereof should flow to the accused. Mere suspicion alone, irrespective of the fact that it is very strong, cannot be a substitute for a proof. The chain of circumstances must be so complete that they lead to only one conclusion, that is, the guilt of the accused." The Court further noted that "the benefit of the doubt with regard to this must flow to the accused" and that several investigative and evidential deficiencies rendered the prosecution story unreliable.

Background

The victim, an elderly woman who lived alone, was found on the morning of 19.12.2016 with asphyxia caused by compression of the neck by a towel; the post‑mortem also recorded prior sexual assault. Two gold bangles were missing from her hands. The complainant’s family lodged an FIR and the local police investigated, collecting blood‑stained material, visiting the scene with a sniffer dog and expert, and recording witness statements. The appellant was alleged to have been a guest at a nearby shared lodging, seen leaving the compound in the early hours by one witness, and later arrested after an encounter in which he allegedly jumped from an over‑bridge and was taken to hospital. At the hospital, an interpreter assisted the police and a witness said the appellant produced two gold bangles from his pocket which were seized.

The trial court convicted the appellant on 17.11.2017 and sentenced him to life and concurrent terms; the Madras High Court dismissed his appeal on 28.10.2021. Before the Supreme Court the appellant argued false implication and insufficiency of proof, stressing the absence of any direct evidence connecting him to the scene. The State relied on circumstantial inferences, the witness accounts and the alleged recovery of the bangles.

Applying settled principles on circumstantial evidence, including authority relied upon in Karakkattu Muhammed Basheer and earlier precedents, the Court identified material lacunae: the absent and undisclosed informant who purportedly led police to the appellant; non‑recording and non‑production of that informant as a witness; the failure to record the statement or associate Marcus, who had last been with the appellant shortly before the likely time of death; absence of forensic links such as fingerprints, blood, hair or skin samples tying the appellant to the body, the recovered articles or the scene; and inconsistencies about how and when the alleged recovery of bangles was effected. The Court observed that these gaps allowed other reasonable hypotheses and prevented a finding beyond reasonable doubt.

The Supreme Court concluded that the prosecution had not produced a "chain of events" so complete as to exclude every hypothesis of innocence and therefore set aside the judgments of the Sessions Court and the High Court, acquitted the appellant Mohamed Sameer Khan, and ordered his release forthwith if not required in any other case. Pending applications stood disposed of.

Case Details: Case No.: Criminal Appeal No. 2069 of 2024 (2025 INSC 1269) Case Title: Mohamed Sameer Khan v. State represented by Inspector of Police Appearances: For the Petitioner(s): [Not indicated in judgment] For the Respondent(s): [Not indicated in judgment]