Whether accused can be acquitted in a Circumstantial Evidence Case?

Facts of the Case:
The incident dates back to February 3, 1997, when the deceased was found dead with multiple injuries in front of Mohan Singh’s shop. The autopsy revealed head injuries as the cause of death. The prosecution alleged that the appellants, Suresh Chandra Tiwari and Bhuwan Chandra Punetha, were involved in the crime due to previous enmity related to local elections in 1996. The case was based on circumstantial evidence, including the deceased being last seen with the appellants and the recovery of certain items linked to the crime.

Contentions of the Appellant:

1. The circumstantial evidence was inconclusive and lacked proximity to the crime.
2. The recovery of incriminating items was neither credible nor properly linked to the accused.
3. Statements under Section 313 CrPC did not include some incriminating circumstances, violating procedural requirements.
4. Alleged disclosures leading to recovery were inadmissible as recoveries occurred prior to recorded statements.
5. The prosecution failed to prove the guilt of the appellants beyond reasonable doubt, and the High Court erred in convicting them based on weak evidence.

Contentions of the Respondent (State):

1. The chain of circumstances was complete and pointed unequivocally to the guilt of the appellants.
2. The recovery of blood-stained stones and other items corroborated the prosecution’s narrative.
3. The appellants’ movements and prior threats to the deceased established their culpability.

Issues Framed:

1. Whether the prosecution established a complete chain of circumstantial evidence pointing to the guilt of the appellants?
2. Whether the incriminating items recovered were admissible and connected to the crime?
3. Whether the appellants’ alleged enmity with the deceased could establish motive sufficiently?
4. Whether the High Court erred in altering the conviction from murder to culpable homicide not amounting to murder?

Observations/Findings by the Supreme Court:

1. The chain of circumstantial evidence was incomplete and failed to exclude other possibilities.
2. The “last seen” evidence and the appellants’ movements lacked proximity and clarity.
3. The recovery of items was not conclusively connected to the crime, with procedural lapses in recording disclosures.
4. Motive alone was insufficient to convict in a case relying entirely on circumstantial evidence.
5. The High Court erred in altering the conviction and reducing the sentence without concrete justification.

Principle of the Case:
Conviction based on circumstantial evidence requires a complete chain of unerring facts that exclude every possibility of innocence and unequivocally point to the guilt of the accused.

Final Order:
The Supreme Court allowed the appeal, set aside the conviction and sentence, and acquitted the appellants. It held that the prosecution failed to prove its case beyond a reasonable doubt.

Impact on Public Law and Order:
This judgment reinforces the necessity for rigorous standards in cases relying on circumstantial evidence. It emphasizes safeguarding against wrongful convictions by ensuring procedural compliance and substantive proof. The ruling highlights the judiciary’s role in upholding justice and preventing misuse of the legal system, thereby strengthening public confidence in law enforcement and judicial integrity.

Case Citation:
Supreme Court of India
Suresh Chandra Tiwari & Anr. vs. State of Uttarakhand
Criminal Appeal No. 1902 of 2013
Judgment Date: November 28, 2024