Absence of Direct Witnesses and Missing Links in Circumstantial Evidence Leads to Acquittal in High-Profile POCSO Case – Patna High Court

In a significant ruling, the Patna High Court overturned the conviction of Guddu Kumar Yadav in a case that had garnered substantial attention. The bench, comprising Honourable Mr. Justice Chakradhari Sharan Singh and Honourable Justice Smt. Gunnu Anupama Chakravarthy, delivered their verdict on November 10^th, setting aside the earlier sentence by the Special Judge, POCSO, Araria.

The appellant, Guddu Kumar Yadav, was previously convicted for offences under Sections 376, 302 of the IPC, and Section 3(2)(v) of the SC/ST Act. However, in a dramatic turn of events, the High Court found crucial gaps in the prosecution’s case.

The Court noted, “In a case of circumstantial evidence, it is for the prosecution to prove link the chain of events in order to connect the crime with the appellant to the extent that guilt of the appellant is the only hypothesis ruling out the possibility of any other inference.” This observation highlighted the importance of a thorough and unbroken chain of circumstantial evidence in criminal proceedings, which was found lacking in this case.

The judgment scrutinized the evide”ce presented, including the absence of direct witnesses and the reliance on a confessional statement, which the court deemed insufficient for a conviction. It was emphasized that “Any missing of the link of chain of the events, benefit of doubt has to be extended to the appellant.”

Medical evidence also played a crucial role in the decision, as the post-mortem report failed to conclusively determine the cause of death and found no signs of sexual assault, further weakening the prosecution’s stance.

The bench pointed out the shortcomings in the investigation, stating, “Admittedly, there are no direct witnesses to the incident, and in a case of circumstantial evidence, it is for the prosecution to prove that the entire chain of events are complete and have formed a ring.” The failure to establish a complete and unbroken chain of evidence led to the acquittal of Yadav.

This landmark judgment reiterates the principle of the presumption of innocence and the necessity for the prosecution to prove guilt beyond a reasonable doubt in criminal cases. The decision has been met with various reactions, sparking discussions about the standards of proof required in criminal justice.

Representing advocates in the case were Mr. Viveka Nand Singh for the appellant and Mr. Binay Krishna, A.P.P., for the respondent. The judgment has set a precedent in cases relying heavily on circumstantial evidence, underscoring the need for meticulous evidence collection and presentation in criminal trials.

Date of Decision: 10-11-2023

Guddu Kumar Yadav @ Guddu Yadav VS The State of Bihar