A complete circumstantial-evidence chain, including an extra-judicial confession, sustains a murder conviction.

The appellant and deceased Popat Gaikwad had worked at the same fruit stall. After the appellant was removed and the deceased was engaged, the appellant allegedly blamed the deceased and the two had quarrelled.

On 30 April 2018, the deceased was found dead with severe head injuries.

The prosecution’s case was that the appellant was apprehended nearby while running, confessed to having assaulted someone with stones, and led those who had detained him to the deceased’s body.

Human blood was detected on the appellant’s jeans, but the blood group was inconclusive.

The Sessions Court convicted him under Section 302 of the Indian Penal Code and sentenced him to life imprisonment; he appealed.

Whether the prosecution proved beyond reasonable doubt a complete chain of circumstances establishing that the appellant murdered the deceased.

Whether the circumstances relied on—including motive, the alleged extra-judicial confession, the appellant’s conduct and presence near the spot, his leading others to the body, and blood on his jeans—were sufficient to sustain the conviction.

The conviction was for murder under Section 302 of the Indian Penal Code.

The Court applied the circumstantial-evidence principle that the prosecution must prove the incriminating circumstances beyond reasonable doubt and establish a complete chain of circumstances against the accused.

It considered motive, an alleged extra-judicial confession, post-incident conduct, knowledge of the location of the body, and blood evidence as circumstances in that chain.

It also referred to Section 428 of the Code of Criminal Procedure, under which the appellant was entitled to set-off.

The Court accepted the evidence of the stall owner and the deceased’s wife as establishing enmity between the appellant and the deceased.

It accepted PW-2’s account that the appellant was seen running with blood on his clothes, admitted assaulting a person with stones, and led those who apprehended him to the body.

The Court also treated human blood on the appellant’s jeans as incriminating, notwithstanding that the blood group was inconclusive, and noted that the appellant had offered no explanation for the circumstances.

Taken together, these circumstances were held to form a complete chain proving the prosecution case beyond reasonable doubt.

It clarified that the appellant was entitled to set-off under Section 428 CrPC, and disposed of the connected interim application.