Supreme Court Quashes Conviction After Finding Investigation "Shabby and Perfunctory" in Child Rape‑Murder Case

A Bench of Justices Vikram Nath, Sanjay Karol and Sandeep Mehta heard appeals against the conviction and death sentence imposed in a case of rape and murder of a child aged about 3 years 9 months. The appeals challenged the trial Court and Bombay High Court decisions that had convicted the accused on circumstantial evidence and confirmed the death penalty.

The Court allowed the appeals, quashed the concurrent convictions and sentences and acquitted the appellant, ordering his release if not required in any other case. The bench observed that the prosecution case rested entirely on circumstantial evidence and that investigation suffered from “shabby and perfunctory investigation” which, coupled with created or padded witness testimony, rendered the chain of circumstances incomplete. The Court noted an “overzealous approach of the Courts below, to impart justice, in a sense that someone must be held responsible for the crime,” and recorded that the accused had endured incarceration for over 12 years with the “Damocles sword of impending death penalty hanging over his head” for more than six years. The Court, in its reasoning, observed: “A close analysis of this decision would show that the following conditions must be fulfilled before a case against an accused can be said to be fully established: (1) the circumstances from which the conclusion of guilt is to be drawn should be fully established... (2) the facts so established should be consistent only with the hypothesis of the guilt of the accused... (3) the circumstances should be of a conclusive nature and tendency, (4) they should exclude every possible hypothesis except the one to be proved, and (5) there must be a chain of evidence so complete as not to leave any reasonable ground for the conclusion consistent with the innocence of the accused...” (quoting the settled tests for conviction on circumstantial evidence).

Background The criminal matter arose from the disappearance on 30 September 2013 of a toddler who had been playing with the family dog; her body was recovered from a pond about one kilometre from a watchmen’s chawl on 2 October 2013. An FIR (Crime No. I‑306/2013) under Section 363 IPC was lodged; later investigations added charges including murder (Section 302), sexual assault (Section 376(2)(i)), and offences under the Protection of Children from Sexual Offences Act. The case proceeded on three principal strands of circumstantial proof relied on by the prosecution: (i) the “last seen together” testimony of local watchmen and neighbours; (ii) an alleged extra‑judicial confession to a supervisor; and (iii) a forensic laboratory report opining similarity between mud on the accused’s shoes and soil from the pond.

Investigation initially proceeded under Assistant Police Inspector Vikas Sarjerao Lokre and was later transferred to Deputy Superintendent Mandar Vasant Dharmadhikari. The trial Court convicted the accused in March 2019 and sentenced him to death and concurrent terms for other offences; the Bombay High Court, by judgment dated 25 November 2021, affirmed conviction and confirmed the death sentence. The appellant approached this Court by special leave.

On scrutiny, the Supreme Court found material deficiencies: the “last seen” witnesses either did not disclose their observations to the first investigating officer despite searches, or made “wholesale improvements” and only recorded statements after the second officer took over, circumstances the Court described as indicative of “padding” of evidence. The Court found the lone witness of extra‑judicial confession to be unreliable and noted that DNA and other FSL tests were inconclusive; the only scientific link (a soil comparison report) was held to be vague, untested by the expert in Court and insufficient to exclude other hypotheses. The Court applied settled law on circumstantial evidence (Sharad Birdhichand Sharda principles) and concluded that the prosecution failed to prove a complete unbroken chain of incriminating circumstances. The Supreme Court therefore quashed the impugned judgments, allowed the appeals and directed that the appellant be released forthwith if not wanted in any other case. Pending applications were disposed of.

Case Details: Case No.: 2025 INSC 702 Case Title: Ramkirat Munilal Goud v. State of Maharashtra & Ors. Appearances: For the Petitioner(s): Raghenth Basant, Senior Counsel For the Respondent(s): Rukhmini Bobde, Standing Counsel, State of Maharashtra