Supreme Court Sets Aside Murder Conviction Citing Incomplete Chain of Circumstantial Evidence and Orders Release

A bench of Justices Abhay S. Oka, Ahsanuddin Amanullah and Augustine George Masih heard the appeal by Murugan challenging the Madras High Court’s judgment which had acquitted him of rioting under Section 148 IPC but had sustained his conviction and life sentence under Section 302 IPC for the death of a police constable. The appeal raised issues relating to reliability of eye‑witness and last‑seen testimony, admissibility of extra‑judicial confessions, delays in presentation of the FIR and the sufficiency of circumstantial evidence.

The Court allowed the appeal, set aside the conviction and sentence under Section 302 IPC and directed that the appellant be released forthwith if not required in any other case. The Court held that once the key testimonial pillars of the prosecution were disbelieved by the High Court — the eye‑witness account, the last‑seen witness and extra‑judicial confessions of co‑accused — the remaining material did not establish a complete chain of circumstances pointing exclusively to the appellant’s guilt. The Court noted that “the evidence of these three crucial witnesses” had been disbelieved and that, in such circumstances, “merely the recovery at the site of the incident of a wheel spanner, which according to the prosecution has fingerprints of the accused on it and three pairs of slippers would not be enough for holding the appellant guilty of having caused the death of the deceased.” The Court, in its reasoning, observed: “Thus, these basic established principles can be summarized 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. Even in the case of a conviction where in an appeal the chain of evidence is found to be not complete or the courts could reach to any another hypothesis other than the guilt of the accused, the accused person must be given the benefit of doubt which obviously would lead to his acquittal. Meaning thereby, when there is a missing link, a finding of guilt cannot be recorded. In other words, the onus on the prosecution is to produce such evidence which conclusively establishes the truth and the only truth with regard to guilt of an accused for the charges framed against him or her, and such evidence should establish a chain of events so complete as to not leave any reasonable ground for the conclusion consistent with the innocence of accused.”

Background The case arose after the body of Special Branch Grade‑I Constable Jagadeesh Durai was found early on 07.05.2018 near a maize field; he had earlier chased a tractor‑trailer allegedly carrying illegally excavated river sand and had informed fellow officers by phone. The police investigation led to arrest of Murugan (A1) and co‑accused; the trial court convicted A1 and A2 under Sections 148 and 302 IPC, sentencing them to three years RI under Section 148 and life imprisonment with fine under Section 302. On appeal, the Madras High Court acquitted some co‑accused, upheld the 302 conviction against A1 and A2 but acquitted them of 148. In the Supreme Court, counsel for Murugan challenged the reliability of the last‑seen witness (who gave his statement 17 days after the incident and had been present at the postmortem), the rejection of the eye‑witness evidence, the inadmissibility of extra‑judicial confessions made while co‑accused were in custody, and the unexplained delay in presenting the FIR to the Magistrate. The State relied on call records, fingerprints on a recovered wheel spanner, three pairs of slippers recovered at the scene and other material. The Supreme Court observed that with the “backbone” of the prosecution case having crumbled — key eyewitness and confession evidence being discarded — the remaining circumstantial evidence did not form an unbroken chain excluding all other hypotheses. The Court followed the principles on circumstantial evidence reiterated in Karakkattu Muhammed Basheer v. State of Kerala and concluded that a missing link obliged acquittal. The appeal was allowed, the conviction and sentence under Section 302 IPC were set aside and the appellant was ordered to be released if not required in any other case. Pending applications stood disposed of.

Case Details: Case No.: CRIMINAL APPEAL NO. 3318 OF 2023 (2025 INSC 446) Case Title: Murugan v. The State represented by the Inspector of Police Appearances: For the Petitioner(s): Advocates’ names not indicated in the judgment For the Respondent(s): Advocates’ names not indicated in the judgment