A broken chain of circumstantial evidence cannot sustain a murder conviction.

The prosecution alleged that Prakash murdered Bheemappa on 22 May 2016 by striking him with stones, motivated by Bheemappa’s alleged relationship with Prakash’s wife.

The prosecution relied on motive, the alleged last-seen circumstances, recovery of the appellant’s clothes, and his identification of the scene.

The Sessions Court convicted him under Section 302 IPC and sentenced him to life imprisonment.

He appealed under Section 374(2) CrPC.

1. Whether the prosecution proved beyond reasonable doubt the circumstantial evidence relied upon to establish that the appellant committed Bheemappa’s murder

2. Whether the conviction and sentence under Section 302 IPC could stand in light of the evidentiary deficiencies identified on appeal

The Court considered the charge of murder under Section 302 IPC and the criminal appeal under Section 374(2) CrPC.

In a case resting on circumstantial evidence, the prosecution must establish the relied-upon circumstances beyond reasonable doubt and show that they form a chain sufficient to prove the accused’s guilt; suspicion or an individual circumstance that does not reliably connect the accused to the crime is insufficient.

Where the evidence leaves reasonable doubt, the accused is entitled to its benefit.

The Court found that the alleged motive was based on the deceased’s relationship with the appellant’s wife, but the complaint neither named the appellant as a suspect nor mentioned that motive; the prosecution also produced no material showing that the appellant had called the deceased to the scene.

The evidence of PW2 and PW3 did not reliably establish that the appellant was with the deceased, and PW2’s account of seeing the appellant run from the spot was not recorded during the inquest.

Neither witness reported seeing blood on the appellant’s clothes, despite the prosecution’s claim that they bore substantial bloodstains; PW3’s statement was recorded more than a month after the incident.

The clothes-recovery evidence was also unreliable: one panch witness did not support the prosecution, the other said the clothes were seized at the police station, and the record contained inconsistencies about the voluntary statement and the timing of the seizure.

Since the scene was already known to police, the appellant’s alleged identification of it was not incriminating.

Taken together, the circumstances did not form a reliable chain proving guilt beyond reasonable doubt.

It allowed the appeal, set aside the conviction and sentence, acquitted the appellant, and directed his release unless required in another case.