Absence of Classical Signs of Strangulation and Possibility of Hanging Nullifies Homicidal Theory: Supreme Court Holds Medical Evidence Alone Cannot Prove Guilt

“Inconclusive Medical Opinion Cannot Sustain Murder Conviction”, In a landmark ruling reinforcing the evidentiary value of medical jurisprudence in criminal trials, the Supreme Court set aside the conviction of two accused for murder, holding that an inconclusive medical opinion—without corroborative circumstantial evidence—cannot form the basis for conviction under Section 302 IPC.

The Court made it clear that where post-mortem findings do not definitively establish homicidal death, and especially where signs of possible suicide by hanging are not ruled out, the benefit of doubt must go to the accused.

“The medical opinion is not conclusive as to a homicide,” observed the Bench of Justice K. Vinod Chandran and Justice Sanjay Kumar, after noting several inconsistencies and contradictions in the prosecution’s theory of strangulation.

“When Medical Evidence Suggests Possibility of Hanging, Prosecution Must Rule Out Suicide” – Apex Court Criticises Gaps in Post-Mortem Analysis

The deceased was found buried in a graveyard and later exhumed for post-mortem, which was conducted by PW2, a medical expert. The report initially opined that the cause of death was “asphyxia by strangulation with a hard, blunt and long rope.” However, during cross-examination, the doctor conceded the possibility of death by hanging.

Crucially, the Court noted that:

• The larynx was intact, which is more common in suicidal hanging than strangulation.
• No blood clots were found in the nostrils, ears, or mouth—typical signs in manual strangulation.
• There was no cyanosis—a purplish discoloration of the nails and face often seen in strangled victims.
• Hyoid bone was broken, but even that, the doctor clarified, could occur in cases of suicidal hanging.

The Court concluded: “It was also opined that it could be a case of suicide by hanging in the instant case… Hence, the medical evidence is not conclusive as to a homicide.”

The Bench stressed that the prosecution failed to reconcile this inconsistency or present independent evidence to conclusively rule out suicide, thereby falling short of proving the guilt of the accused beyond reasonable doubt.

“Burial of Body May Raise Suspicion, But Suspicion Alone Is Not Proof of Murder”: Supreme Court Cautions Against Overreliance on Circumstantial Suspicion

The fact that the deceased’s body was found buried was treated by the High Court as a critical circumstance implying foul play. However, the Supreme Court drew a fine legal distinction, holding that suspicion—even if strong—cannot substitute proof.

“Even if the death was by hanging, the body was exhumed from where it was buried, which raises strong suspicions at least as to the burial of the body,” the Court remarked. But it cautioned that such suspicion, in the absence of independent evidence proving homicide, cannot result in conviction under Section 302 IPC.

The Court also found that no valid discovery statement was made under Section 27 of the Indian Evidence Act, to connect the burial to the accused, nor was the alleged murder weapon—a rope—linked forensically to the act of strangulation.

“Medical Evidence Must Align with Other Circumstances to Prove Murder” – Court Emphasises Need for Full Chain of Circumstances

Referring to the well-settled five-fold test laid down in Sharad Birdhichand Sarda v. State of Maharashtra, the Supreme Court held that the chain of circumstances was incomplete, especially since the medical cause of death was itself in question.

The Court reiterated: “Inconclusive medical opinion cannot sustain conviction without strong corroborative circumstantial evidence.” The trial court had rightly refused to rely solely on medical opinion, and the High Court erred in treating it as conclusive proof of homicidal death.

This ruling serves as a significant judicial reminder that medical evidence, while crucial, must not be stretched beyond its probative value, and that its reliability depends on its harmony with other facts on record.

Acquittal Restored, Medical Opinion Held Insufficient for Murder Conviction

In conclusion, the Supreme Court found that no homicidal cause of death was proved, no motive was established, and all other circumstances—last seen, discovery, recovery, confessions—either failed or lacked legal sanctity. The Court restored the Trial Court’s acquittal and set aside the High Court’s reversal.

“If the accused are still in jail, they shall be released forthwith unless required in any other case. If already released on bail, the bail bonds stand cancelled,” the Court directed.

Date of Decision: 27 January 2026