“A Criminal Trial Is Not A Fairy Tale Where Imagination Replaces Evidence”: Supreme Court Reiterates in Acquittal of Death Row Convict

“Prosecution Must Prove Circumstances Beyond All Reasonable Doubt; Strong Suspicion Cannot Replace Legal Proof”, In a significant verdict Supreme Court of India set aside the conviction and death sentence of a man accused of a double murder and rape, castigating the prosecution for relying solely on circumstantial evidence riddled with glaring loopholes. The Court emphatically held that “the prosecution must prove its case beyond reasonable doubt, and the fractured chain of circumstances in this case fails to meet that standard.” This landmark judgment not only resulted in the acquittal of the appellant but also led to important directives on the handling of DNA evidence in criminal cases.

The origins of the case lay in the tragic deaths of two young individuals who went missing on 14th May 2011 after visiting Suruli Falls, Tamil Nadu. Days later, their decomposed bodies were found, and the police, acting on dubious ‘last seen’ evidence, arrested the appellant. The prosecution alleged that the appellant raped the female victim and murdered both for a gold chain, relying on circumstantial evidence, recoveries under Section 27 of the Evidence Act, and DNA matching to secure a conviction.

The Trial Court sentenced the appellant to death, calling it a “brutal and cold-blooded crime,” a sentence which was upheld by the Madras High Court. However, on appeal, the Supreme Court scrutinized the entire prosecution case and found the conviction untenable.

“A Chain With Missing Links Cannot Hang a Man”: Court on Circumstantial Evidence

The Supreme Court began its analysis by restating the bedrock principle of criminal jurisprudence. Quoting the celebrated decision in Sharad Birdhichand Sarda v. State of Maharashtra, it observed:

“There must be a chain of evidence so complete as not to leave any reasonable ground for the conclusion consistent with the innocence of the accused.”

Applying this principle, the Court noted that the prosecution had failed to establish any such unbroken chain of circumstances. The mere fact that the deceased were seen at the location where their bodies were later found, in itself, could not implicate the appellant.

“Star Witness Turns Spectator”: Supreme Court Discards Unnatural Silence in ‘Last Seen’ Testimony

The cornerstone of the prosecution’s case was the testimony of PW-5, who claimed to have seen the appellant threatening the victims. The Supreme Court expressed disbelief at the unnatural conduct of this witness, remarking:

“Knowing both the victims, having seen them threatened, learning that they were missing, and still remaining silent for six days—such conduct is simply inexplicable and cannot be reconciled with the behaviour of a reasonable man.”

The Court found that the High Court had erred by overlooking the glaring inconsistencies in the witness's statement, especially his contradictory explanations for his silence and his dubious identification of the accused in court after having seen him in police custody.

“Test Identification Parade Conducted After Publicity Is Legally Meaningless”: Court on TIP Evidence

Turning to the Test Identification Parade (TIP), the Court lambasted the flawed process, observing:

“When the accused is shown to a witness during police interrogation or in media coverage before a Test Identification Parade, the purpose of such an exercise is entirely defeated.”

The Court cited precedents including Budhsen v. State of U.P. to conclude that the TIP carried no evidentiary value, noting the dangerous precedent of convicting a man based on such contaminated identification.

“A Recovery Without a Reliable Link Is No Proof of Guilt”: Court on Section 27 Recoveries

Regarding the alleged recovery of a gold chain and a sickle, the Court concluded that the prosecution had not conclusively proved these items’ connection to the crime. It stated:

“In a case of murder for gain, when the stolen property is not unmistakably identified, and other valuables remain unrecovered, suspicion cannot be converted into guilt.”

The Court also found it inexplicable that forensic analysis was not conducted on the sickle, the alleged murder weapon, and criticized the investigating authorities for their careless approach.

“DNA Evidence Without Chain of Custody Is Worse Than No Evidence”: Supreme Court Sets Aside Scientific Evidence

A crucial plank of the prosecution’s case was DNA matching. Yet the Court sternly rejected the evidence, highlighting:

“When DNA samples are mishandled, kept for 41 days without refrigeration, passed through unknown hands, and transported without accountability, the possibility of contamination cannot be ruled out.”

The Court drew attention to the dangerous laxity in the handling of biological evidence and lamented that such mismanagement could sabotage even the most powerful forensic tool. It was unequivocal in its conclusion:

“Despite matching reports, the DNA evidence here is rendered inadmissible due to a broken chain of custody.”

“Robbery Alleged but Motive Missing”: Court Finds Prosecution Failed to Establish Motive

The Supreme Court scrutinized the supposed motive of robbery and found it untenable. It remarked:

“Where personal belongings like mobile phones and other ornaments were neither stolen nor recovered, and no credible motive is established, the hypothesis of guilt remains incomplete.”

The Court noted that the mere recovery of a gold chain of commonplace design, without corroborative evidence, could not seal a death verdict.

“Selective Investigation Is a Travesty of Justice”: Court Rebukes Police for Ignoring Other Suspects

A damning part of the judgment was the Court’s scathing criticism of the police investigation. It questioned:

“Why were other suspects named by the victim’s family not pursued? Why was Bhagyalakshmi, the closest eyewitness, kept out of the witness box?”

Referring to Takhaji Hiraji v. Thakore Kubersing Chamansing, the Court emphasized that the non-examination of such a crucial witness was fatal to the prosecution case, stating:

“Suppression of material witnesses corrodes the integrity of the criminal trial.”

“DNA Evidence Must Be Handled With Forensic Discipline, Not Casual Negligence”: Supreme Court Issues Pan-India Guidelines

In a rare exercise of its constitutional powers, the Court laid down binding directions for all states regarding the handling of DNA evidence. It mandated:

“Chain of custody registers must be maintained, samples dispatched within 48 hours, and no unauthorized opening permitted.”

The Court directed the judgment to be circulated among all High Courts and State Police Chiefs, stressing:

“Scientific evidence, if mismanaged, leads not to conviction of the guilty but miscarriage of justice.”

“A Day of Reckoning May Arrive for Compensation to the Wrongly Incarcerated”: Court Invokes Article 21

Expressing grave concern over the years of wrongful incarceration suffered by the appellant, the Supreme Court noted:

“Where clean acquittals are granted after long years of incarceration, there arises a constitutional question under Article 21 whether such individuals are entitled to compensation.”

Though the Court stopped short of granting compensation, it placed the issue squarely before Parliament, reminding:

“We are not breaking new ground, but reaffirming the constitutional guarantee of the right to life and personal liberty.”

With this historic ruling, the Supreme Court has reinforced the sacrosanct principle that criminal convictions must rest on unimpeachable evidence, especially when life and liberty are at stake. The Court’s powerful words serve as a reminder to all courts and investigative agencies that the goal of criminal justice is not to convict at any cost, but to ensure that only the guilty are punished and the innocent are protected.

Date of Decision: 15th July 2025