Court Cannot Convict One Accused And Acquit Another On Same Evidence: Supreme Court Acquits Murder Convict

Supreme Court of India, in a significant ruling dated April 07, 2026, held that a conviction cannot be sustained solely on circumstantial evidence if the chain of events is not conclusively established. A bench comprising Justice Prashant Kumar Mishra and Justice Vipul M. Pancholi acquitted a murder convict, observing that when two accused are implicated on identical evidence, the court cannot convict one while acquitting the other. The Court emphasized that a legally tenuous recovery of weapons and the uncorroborated testimony of an interested witness cannot replace the standard of proof beyond a reasonable doubt.

The appellant, Gautam Satnami, was convicted by a trial court for the murder of a man using an axe, and was sentenced to life imprisonment under Section 302 of the Indian Penal Code (IPC). The prosecution's case rested entirely on circumstantial evidence, including a "last-seen" testimony, the recovery of a blood-stained axe, and alleged prior enmity. A co-accused in the same trial was acquitted on identical forensic and recovery evidence, but the appellant's conviction was upheld by the High Court of Chhattisgarh, prompting the present appeal before the Supreme Court.

The primary question before the Court was whether the chain of circumstantial evidence against the appellant was complete and conclusive enough to sustain a murder conviction. The Court was also called upon to determine if the appellant was entitled to the benefit of the principle of parity, given that a co-accused was acquitted by the trial court on similar evidentiary grounds.

Golden Principles Of Circumstantial Evidence

The Court began its analysis by recalling the five "golden principles" of circumstantial evidence laid down in the landmark Sharad Birdhi Chand Sarda case. The bench noted that in cases lacking direct evidence, the circumstances from which the conclusion of guilt is drawn must be fully and firmly established. The judges emphasized that the prosecution's chain of evidence must be complete and consistent only with the hypothesis of guilt, leaving no reasonable ground for innocence.

Unreliable "Last-Seen" Testimony

Examining the core of the prosecution's case, the Court heavily scrutinized the "last-seen" testimony of a key witness who claimed to have seen the appellant carrying an axe near the deceased's house at night. The bench observed that the spot was usually covered in darkness and the visual identification was allegedly made only in the light of a motorcycle headlight. The Court pointed out that the medical evidence failed to fix the time of death with enough precision to conclusively correlate the appellant's presence with the commission of the offence.

Distinction Between "Related" And "Interested" Witnesses

Addressing the credibility of the "last-seen" witness, the Court found that he and his associates harboured longstanding hostility towards the appellant due to previous disputes. The bench clarified the distinction between related and interested witnesses, noting that a witness becomes "interested" when they have a motive to falsely implicate an accused to see them punished. The Court concluded that the possibility of this witness being an interested party could not be ruled out, rendering his uncorroborated testimony legally insufficient.

"When there is similar or identical evidence of eyewitnesses against two accused by ascribing them the same or similar role, the Court cannot convict one accused and acquit the other."

Doubtful Recoveries And Hostile Witnesses

The Court then turned its attention to the alleged recoveries of a blood-stained axe and clothes made under Section 27 of the Indian Evidence Act. The judges highlighted that the forensic report merely confirmed the presence of human blood but failed to determine the blood group or definitively link the weapon to the fatal injuries. Crucially, the Court noted that independent witnesses to the seizure memorandums had either turned hostile or admitted their signatures were obtained after the fact. The bench noted that this made the recovery circumstance legally tenuous.

Application Of The Principle Of Parity

Drawing a crucial comparison, the bench observed that the trial court had acquitted the co-accused on the exact same forensic and circumstantial evidence. The Supreme Court applied the principle of parity, asserting that similar cases must be decided alike to prevent discrimination in the criminal justice system. The bench reasoned that since the co-accused was given the benefit of doubt regarding the weak recovery evidence, the present appellant was equally entitled to the same standard of judicial relief.

Motive Alone Cannot Establish Guilt

Finally, the Court addressed the prosecution's reliance on prior enmity between the appellant and the deceased as a motive for the murder. The bench held that while motive is a supporting factor that can strengthen an otherwise complete chain of evidence, it cannot replace the chain itself when other crucial circumstances are missing. The judges observed that the evidence failed to establish any immediate or grave animosity that would conclusively precipitate such a crime.

The Supreme Court allowed the appeal, setting aside the judgments of both the High Court and the Sessions Court. Holding that the prosecution's case failed at the threshold to establish a firm and complete chain of circumstances, the Court acquitted the appellant of the murder charge and ordered the discharge of his bail bonds.

Date of Decision: 07 April 2026