Must Be Proved, Not May Be Proved: Karnataka High Court Upholds Triple Murder Conviction On Complete Chain Of Circumstantial Evidence

“When Circumstances Form An Unbroken Chain, Guilt Becomes Inescapable”, On 06 February 2026, the High Court of Karnataka at Bengaluru affirming the conviction of Accused Nos.1 to 3 for offences under Sections 302, 397 and 201 read with Section 34 of the Indian Penal Code, 1860. The Division Bench comprising Justice H.P. Sandesh and Justice Venkatesh Naik T held that the prosecution had successfully established a complete and unbroken chain of circumstantial evidence, leaving no room for any hypothesis consistent with innocence.

The Court reiterated the settled principle that in cases based purely on circumstantial evidence, the prosecution must cross the threshold of “must be proved” and not merely “may be proved”, and found that standard fully satisfied in the present case.

“Borrowed Money Became The Motive For Murder”

The prosecution case traced the genesis of the crime to a financial dispute. The deceased, Chinna Yarriswamy, had lent Rs.2 lakh to the accused. Persistent demands for repayment allegedly pushed the accused to hatch a plan to eliminate him.

The Court noted that evidence of the wife and close relatives of the deceased clearly established that the accused were unable to repay the loan and intended to avoid repayment altogether. Accepting the prosecution narrative, the Bench observed that the accused lured the deceased on the pretext of showing him “treasure” near Boredevara Temple, where the murder was ultimately committed.

“Medical Evidence Leaves No Doubt Of Homicidal Death”

The Bench undertook a detailed analysis of the medical and inquest evidence. The dead body, exhumed from a forest area at Doddaullarthy Kaval, revealed multiple grievous injuries.

Referring to the post-mortem findings, the Court recorded that:

“Penetration present over front of neck… facial bones and skull bones fractured at multiple places… brain matter drained out through the skull.”

The medical expert unequivocally opined that death was due to multiple stab and crush injuries, fully corroborating the prosecution version of a violent homicidal death caused with choppers and stones.

“Last Seen Theory Firmly Established By Independent Witnesses”

A crucial pillar of the prosecution case was the last seen theory. The Court relied on the consistent testimony of dhaba staff, villagers, and relatives who saw the deceased travelling with the accused in a Tata Ace vehicle towards the place of occurrence shortly before his disappearance.

Applying the ratio of State of U.P. v. Satish, the Bench emphasized that the proximity of time and place ruled out the involvement of any third party. Significantly, the accused offered no explanation whatsoever as to how they parted company with the deceased.

The Court held that such silence justified drawing an adverse inference, observing that:

“When an accused fails to explain how and when they parted ways with the deceased, the presumption of guilt becomes strong.”

“Recovery Under Section 27 Is A Powerful Incriminating Link”

One of the strongest circumstances against the accused was the recovery of stolen articles at their instance under Section 27 of the Indian Evidence Act, 1872. Gold chain, rings, a Titan watch, mobile phone and clothes of the deceased were recovered from the houses of the accused pursuant to their voluntary statements.

Relying on Pulukuri Kottayya v. King Emperor, the Court reiterated that discovery of facts within the exclusive knowledge of the accused lends a guarantee of truth to the information supplied.

The Bench found the recovery evidence to be cogent, lawful and fully proved through panch witnesses and the Investigating Officer.

“Extra-Judicial Confession, Though Weak, Gains Strength From Corroboration”

The prosecution also relied upon an extra-judicial confession made by the accused before a village elder and former Sarpanch. While acknowledging that such confessions are ordinarily weak evidence, the Court held that in the present case it inspired confidence and stood amply corroborated by other circumstances.

Quoting Sahadevan v. State of Tamil Nadu, the Bench reaffirmed that an extra-judicial confession can form the basis of conviction when it is voluntary, truthful and supported by a chain of cogent evidence.

“Section 106 Evidence Act Completes The Chain”

Invoking Section 106 of the Indian Evidence Act, the Court held that facts relating to the murder and possession of the deceased’s belongings were within the exclusive knowledge of the accused. Their failure to offer any explanation regarding these incriminating circumstances provided an additional link in the chain of evidence.

The Bench observed that once the prosecution establishes foundational facts, the burden shifts to the accused to explain circumstances peculiarly within their knowledge.

Dismissing both appeals, the Karnataka High Court held that the prosecution had proved every circumstance—motive, homicidal death, last seen together, recovery, identification of property, extra-judicial confession and conduct of the accused—beyond reasonable doubt.

The Court concluded:

“The circumstances proved form a complete chain unerringly pointing to the guilt of the accused and totally inconsistent with their innocence.”

Accordingly, the conviction and sentence imposed by the Sessions Court, Chitradurga, were affirmed in toto.

Date of Decision: 06 February 2026