The judges expressed their view that if any of the connections in the chain of circumstantial evidence are absent or unproven, the conviction of the accused should be overturned.
In a recent case involving a 22-year-old homicide, the Supreme Court emphasized the importance of a comprehensive chain of evidence in cases relying on circumstantial evidence. The court stated that the chain must be complete in all respects and must exclude any alternative theories.
The division bench comprising Justices Vikram Nath and Ahsanuddin Amanullah further stated that if there are any missing or unverified links in the chain of circumstantial evidence, the case against the accused would collapse.
“The law on this matter is well established: in cases relying on circumstantial evidence, the chain of evidence must be comprehensive in order to establish the accused’s guilt and rule out any other plausible theories,” the court ruling explained.
The Court made this observation while allowing an appeal challenging the 2010 decision of the Madhya Pradesh High Court, which upheld the appellant’s conviction under Section 302 of the Indian Penal Code (IPC) pertaining to homicide.
In this particular case, the circumstantial evidence presented by the police against the appellant included motive, last seen, and the recovery of a weapon used in the assault.
The High Court concluded that two of these connections, namely motive and last seen, had been proven. However, the third link, which was the recovery of the weapon, was considered unproven or invalid.
Despite this, the High Court upheld the appellant’s conviction for homicide.
In a subsequent appeal, the Supreme Court found fault with the High Court’s approach.
Citing previous judgments such as Sharad Birdichand Sharda v. State of Maharashtra (1984) and Sailendra Rajdev Pasvan v. State of Gujarat (2020), the apex court stated,
“If the High Court determined that one of the links was missing and unproven, the conviction should have been overturned in accordance with the settled law on the subject.”
Consequently, the Supreme Court reversed the appellant’s conviction and allowed the appeal.
