A Chain of Circumstantial Evidence Must Be Complete and Consistent: Calcutta High Court Overturns Conviction in 2015 Murder Case

Calcutta High Court in Ranadip Banerjee @ Rinku v. State of West Bengal (C.R.A. 479 of 2017) overturned the conviction of Ranadip Banerjee, who was previously sentenced to life imprisonment for the murder of his cousin, Sudip Banerjee @ Piklu. The Court ruled that the prosecution had failed to establish a complete and consistent chain of circumstantial evidence, thus acquitting Ranadip.

In 2015, Sudip Banerjee, who suffered from neurological issues and lived with his brother Ranadip, was found dead in their shared home in Kolkata. Sudip's cousin, Joydeep Banerjee, filed a complaint alleging that Ranadip had assaulted and murdered Sudip. The trial court convicted Ranadip under Section 302 of the Indian Penal Code. The case relied heavily on circumstantial evidence, including witness testimonies that described previous altercations between the brothers.

Ranadip appealed to the High Court, arguing that the evidence against him was insufficient and that there were significant inconsistencies in the prosecution’s case.

The key issue was whether the circumstantial evidence presented by the prosecution was sufficient to prove Ranadip’s guilt beyond a reasonable doubt. The defense pointed to several inconsistencies in the testimonies of key witnesses, including discrepancies in the timeline of events and contradictions regarding the victim’s condition.

The Court reviewed the testimonies of 21 prosecution witnesses. Notably, the primary witnesses—Joydeep Banerjee (PW 3), Noa (PW 4), and Champa (PW 5), the maid—offered conflicting versions of events. For example, PW 4 claimed that Sudip was in good condition in the evening, while PW 3 stated that Sudip was too injured to eat, casting doubt on the reliability of their accounts.

The Court also noted the absence of crucial witnesses, such as the tenants of the house and neighbors, who could have provided independent corroboration of the events. Additionally, there was no forensic evidence linking Ranadip to the alleged murder weapon—a blood-stained iron pipe recovered from the crime scene.

The Calcutta High Court found that the prosecution failed to establish a conclusive and unbroken chain of circumstantial evidence. The Court relied on the principles laid down by the Supreme Court in Sharad Birdhichand Sarda v. State of Maharashtra, which require that circumstantial evidence must lead to only one hypothesis—the guilt of the accused. In this case, the evidence was insufficient to rule out other possibilities.

The Court highlighted several shortcomings in the investigation, including the failure to record statements from independent witnesses, such as neighbors and tenants, and the lack of forensic analysis of key evidence.

"The prosecution has miserably failed to form a chain of circumstances leading to the commission of the crime, much less prove it beyond all reasonable doubt based on oral and documentary evidence."

The Calcutta High Court acquitted Ranadip Banerjee, citing the prosecution’s failure to establish a complete and consistent chain of circumstantial evidence. The judgment reinforces the principle that in cases relying on circumstantial evidence, the prosecution must eliminate all reasonable doubt.

Date of Decision: October 4, 2024

Ranadip Banerjee @ Rinku v. State of West Bengal