“Supreme Court Sets Aside High Court’s Conviction in Murder Case: ‘Chain of Circumstances Clearly Incomplete’”

On September 6, 2023 – In a landmark judgment, the Supreme Court of India set aside the High Court of Karnataka’s conviction of the appellant in a murder case under Section 302 of the IPC. The apex court bench, comprising Justices VIKRAM NATH and AHSANUDDIN AMANULLAH, stated that the “chain of circumstances is clearly incomplete,” thereby allowing the appeal and discharging the appellant from the liability of his bail bonds.

The case revolved around the reversal of an acquittal by the High Court, which had convicted the appellant based on circumstantial evidence and the ‘last seen theory.’ The Supreme Court, however, found major discrepancies between the charge framed and the testimonies of witnesses regarding who was last seen with the deceased. “This raised doubts about the veracity of the statements and the application of the ‘last seen theory,’” the Court observed.

The judgment further noted that there was a significant time gap between the alleged last seen and the recovery of the body. “In the absence of corroborative evidence, it cannot be said that the chain of circumstances is so complete that the only inference that could be drawn is the guilt of the appellant,” the Court stated.

The Supreme Court also emphasized the principle of the presumption of innocence, stating that in cases of acquittal, there is a “double presumption in favor of the accused.” The Court added, “When two views are possible, the one favoring the accused should be preferred.”

Legal experts see this judgment as a significant reiteration of the principle that the burden of proof lies with the prosecution and that the accused is presumed innocent until proven guilty.

The judgment has been lauded for its meticulous examination of the evidence and its upholding of the principles of justice and fairness. With this decision, the Supreme Court has once again asserted the importance of a complete and unbroken chain of circumstances for a conviction based on circumstantial evidence.

Date of Decision: September 6, 2023

SREENIVASA vs STATE OF KARNATAKA