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by sayum
05 December 2025 8:37 AM
“Suspicion, However Grave, Cannot Substitute Proof” — Madras High Court reversing the conviction of five men sentenced to life imprisonment for the brutal murder and dismemberment of a businessman. The Division Bench of Justice N. Sathish Kumar and Justice M. Jothiraman held that circumstantial evidence, in the absence of credible corroboration, cannot serve as the basis of conviction, no matter how disturbing the crime may be.
The case had sent shockwaves in 2014 when the decapitated and dismembered body of the victim, a real estate businessman, was found in different locations. The Trial Court had convicted the accused based on extra-judicial confessions, motive over a land dispute, and recoveries allegedly made pursuant to the confessions.
However, the High Court dismantled each link of the prosecution’s case, observing:
“Courts must resist the temptation to tilt towards conviction merely because the crime is heinous—law demands proof, not sympathy.”
“Extra-Judicial Confession is a Weak Form of Evidence—Here, It Was Deeply Suspect”
A central pillar of the prosecution’s case was an alleged extra-judicial confession by Accused No.2 to the Village Administrative Officer (P.W.4). The Court scrutinized the confession document and found serious irregularities. The accused's signature did not match other signatures taken on the same day, and there was a significant delay in producing the confession before the Magistrate.
In words that reflect constitutional caution, the Court declared:
“We find that the confession was not voluntary, appears orchestrated, and does not inspire the confidence necessary for a conviction. A confession manufactured in convenience cannot meet the standards of proof demanded in criminal law.”
The Court relied on the Supreme Court’s decision in Ramu Appa Mahapatar v. State of Maharashtra where extra-judicial confessions were held to be "inherently weak" and requiring strong corroboration. In the present case, there was none.
“The Chain of Circumstantial Evidence Must Be Unbroken—Here, It Was Full of Gaps and Inconsistencies”
The High Court made it clear that in a case based entirely on circumstantial evidence, each link must be proven beyond doubt and must form a complete chain pointing only to the guilt of the accused. However, in this case, it noted several broken links:
There was no forensic evidence to connect the accused to the body or the scene of crime. The body was found in three separate parts, yet no bloodstains or biological evidence were recovered from the alleged crime instruments like the knife, the rock used for dismemberment, or the van used to transport the body.
The “last seen” theory was also rejected as improbable. The prosecution claimed the deceased was last seen with the accused on 17.12.2014, but phone call records showed he used his mobile on 18.12.2014, contradicting the alleged time of death.
The Court observed:
“Suspicion, no matter how grave, cannot be a substitute for legal proof. The 'last seen' evidence is shaky and fails under the weight of technological evidence.”
“Motive Alone Cannot Sustain a Conviction—Criminal Law Requires More Than Suspicion Dressed as Proof”
The prosecution tried to establish motive by pointing to a land dispute between Accused No.1 and the deceased. However, the High Court rejected the argument, stating:
“A strong motive does not eliminate the need for evidence. The motive here was speculative and not backed by documentary proof or independent corroboration.”
The Bench quoted the Supreme Court’s dictum from Vijay Singh @ Vijay Kr. Sharma v. State of Bihar, reiterating that:
“Even the strongest motive, if unsupported by evidence, is not sufficient for conviction in a case resting on circumstantial links.”
“Witnesses and Recoveries Appear Orchestrated—Same Officer Witnessed All Confessions and Seizures”
The Court expressed deep concern over the role of P.W.4, the Village Administrative Officer, who was cited as a witness in all confessions and recoveries. Describing it as “an improbable coincidence”, the Court held that it creates a serious shadow of doubt over the credibility of recoveries.
Further, the gold chain and ring allegedly recovered were not mentioned in the original complaint by the victim's wife. There was no clear identification, and the Court noted that “in absence of specific description, weight, or photographs, such recoveries are unreliable.”
“Flawed Investigation Cannot Be Cured by Emotion—The Court Must Stand Guard for Due Process”
The High Court did not shy away from highlighting the police’s failure to conduct proper investigation. It observed that despite the gravity of the offence, the prosecution failed to conduct scientific tests, ignored call data records, and failed to record the most crucial events promptly.
In scathing terms, the Court stated:
“The investigation appears tailored to fit a narrative rather than discover the truth. Such lapses strike at the root of the prosecution’s case.”
“Justice Must Be Blind to Emotion and Guided by Evidence—Not All Crimes Can Be Solved, But No Innocent Must Be Punished”
Reversing the trial court’s conviction, the Bench held:
“Courts are not concerned with solving a mystery. They are duty-bound to ensure that no man is punished without cogent and legally admissible proof. In this case, the story is grim, but the proof is absent.”
The Court cautioned that emotional pull must never override constitutional mandate.
“The criminal justice system does not allow convictions based on conjectures and surmises. Proof is the fulcrum, not presumption.”
The Madras High Court set aside the convictions, acquitted all five accused, and dismissed the criminal revision petition seeking enhancement of sentence. The bail bonds were ordered to be cancelled, and any fine paid by the appellants was directed to be refunded.
Date of Decision: 27 October 2025