Facts:
The case involves the murder of Hamida Parween, allegedly by her in-laws over a property dispute concerning Holding No. 13, where both parties resided. After her disappearance on March 11, 1997, her body was found locked inside the house. Post-mortem confirmed her death by strangulation. The prosecution relied on circumstantial evidence, including property disputes and the accused’s alleged presence at the crime scene.
Contentions of the Appellant:
The appellants argued that the case was based solely on circumstantial evidence, lacking direct proof of their involvement. They claimed the prosecution failed to establish motive, prove the “last seen” theory, or provide concrete evidence of their presence during the crime. They also criticized investigative lapses, including the non-production of key documents.
Contentions of the Respondent:
The State argued that the appellants had a strong motive driven by a long-standing property dispute. They highlighted that the appellants were last seen quarrelling with the victim and later absconded. They invoked Section 106 of the Indian Evidence Act, asserting that the burden to explain the circumstances rested on the accused. The prosecution also cited medical evidence corroborating the cause of death.
Issues:
- Whether the prosecution successfully established a motive for the accused.
- Whether the appellants were last seen with the deceased.
- Whether the burden of proof shifted to the appellants under Section 106 of the Indian Evidence Act.
- Whether the appellants were guilty based solely on circumstantial evidence.
Observations/Findings by the Supreme Court:
The Court found significant gaps in the prosecution’s case, including the failure to prove motive, establish exclusive presence of the accused at the crime scene, and produce critical evidence. The “last seen” theory and invocation of Section 106 were deemed inapplicable due to lack of corroborative evidence.
Principle of the Case:
The principle established is that in criminal cases based solely on circumstantial evidence, the prosecution must present a complete chain of evidence, leaving no room for alternative hypotheses. Any missing link in this chain benefits the accused under the doctrine of reasonable doubt.
Final Order:
The Supreme Court reversed the convictions, acquitting all accused due to insufficient evidence. They also extended this benefit to a co-accused who had not appealed, invoking Article 142 of the Constitution.
Impact on Public Law and Order:
This judgment underscores the necessity of thorough investigations and adherence to procedural requirements in criminal trials. It reinforces the principle that mere suspicion cannot substitute for proof beyond a reasonable doubt, ensuring protection against wrongful convictions.
Case Citation:
Supreme Court of India, Nusrat Parween vs. State of Jharkhand, Criminal Appeal Nos. 458 of 2012 & 2032 of 2017, Judgment dated December 10, 2024.
