Facts of the Case
The appellant, Wadla Bheemaraidu, was convicted by the Family Court-cum-VII Additional Sessions Judge, Mahabubnagar, for charges under Sections 302 (murder), 364 (abduction), 384 (extortion), and 201 (causing disappearance of evidence) of the Indian Penal Code (IPC). The conviction was affirmed by the High Court of Telangana. The prosecution’s case was based on circumstantial evidence, alleging that the appellant murdered K. Nagesh, with whom his wife had an alleged extramarital affair. Skeletal remains allegedly belonging to the deceased were recovered and matched through DNA profiling. The appellant challenged the concurrent findings of the lower courts before the Supreme Court.
Contentions of the Appellant
The appellant contended that:
- The case was fabricated and based on weak circumstantial evidence.
- The prosecution failed to establish motive, as key witnesses, including the deceased’s family and the appellant’s wife, denied allegations of an extramarital affair.
- The recovery of skeletal remains was not credibly linked to the appellant, and DNA evidence lacked procedural authenticity since the mother’s blood sample collection was not established.
- The recovery process and other circumstantial links were fraught with inconsistencies, breaking the chain of evidence.
Contentions of the Respondent
The State argued that:
- The motive was established through the appellant’s animosity towards the deceased due to his extramarital affair with the appellant’s wife.
- The skeletal remains were recovered based on the appellant’s disclosure and were conclusively identified through DNA profiling, linking the crime to the appellant.
- Two courts had concurrently found the appellant guilty based on evidence, and the Supreme Court should refrain from interfering with these findings.
Issues in the Judgment
- Whether the prosecution established the chain of circumstantial evidence conclusively and beyond reasonable doubt.
- Whether the alleged recoveries and DNA profiling were legally and procedurally valid to convict the appellant.
Observations/Findings by the Supreme Court
The Supreme Court observed:
- The prosecution failed to establish motive as key witnesses, including the deceased’s parents, denied any illicit relationship between the deceased and the appellant’s wife.
- The disclosure statement under Section 27 of the Indian Evidence Act was not proved as voluntary or credible. Additionally, the Investigating Officer’s testimony was inconsistent and failed to show that the appellant led the recovery process.
- The DNA profiling evidence was invalid since no credible evidence showed the deceased’s mother’s blood samples were collected.
- The circumstantial evidence presented by the prosecution did not meet the standards required to prove guilt beyond all reasonable doubt.
Principle of the Case
In cases based on circumstantial evidence, every link in the chain of events must be conclusively established, and procedural lapses in critical evidence, like recovery and forensic testing, render the prosecution’s case untenable.
Final Order
The Supreme Court set aside the judgments of the trial and High Courts, acquitted the appellant, and ordered his immediate release, unless required in any other case.
Impact on Public Law and Order
This judgment underscores the importance of adhering to strict procedural standards in cases relying on circumstantial evidence. By emphasizing the need for credible and unbroken chains of evidence, it safeguards individuals against wrongful convictions and reinforces public trust in the judicial process. The decision serves as a reminder for law enforcement to uphold evidentiary and procedural integrity in criminal investigations.
Case Citation
Supreme Court of India, Wadla Bheemaraidu v. State of Telangana, Criminal Appeal No. 573 of 2023, Judgment dated 3rd December 2024.
