Acquittal must stand where circumstantial evidence fails to establish a complete chain of guilt.

On 20 March 2012, an unidentified and highly decomposed male body, apparently 7–8 days old, was recovered from a drain near village Nigohan. An inquest was conducted and the body was sent for post-mortem examination.

On 25 July 2012, Bhailal alleged that his son, Rambhajan alias Pintu, had left on 10 March 2012 with Tribhuvan to work at the house of accused Ramgulam and had not returned. After allegedly finding a pair of socks near the drain, Bhailal claimed that the recovered body was that of his son and accused Tribhuvan and Ramgulam of murder and disposal of the body.

A charge-sheet was filed under Sections 302 and 201 of the Indian Penal Code; Tribhuvan’s trial was subsequently separated after he was declared a juvenile.

Ramgulam was acquitted by the Additional District and Sessions Judge, Lucknow, on 4 September 2023, principally because the prosecution failed to establish a complete chain of circumstantial evidence, including the identity of the deceased and any last-seen connection between the deceased and Ramgulam.

The State challenged the acquittal in the present government appeal.

Whether the trial court’s acquittal of Ramgulam was perverse, legally unsustainable, or based on a misappreciation of the evidence so as to warrant interference in an appeal against acquittal?

Whether the prosecution established, beyond reasonable doubt, a complete and unbroken chain of circumstantial evidence—including the identity of the deceased, the accused’s last-seen connection with him, and the accused’s involvement in the murder and disposal of the body under Sections 302 and 201 IPC?

The Court considered the offences alleged under Sections 302 and 201 of the Indian Penal Code and the appellate jurisdiction under Section 378 of the Code of Criminal Procedure.

In an appeal against acquittal, the appellate court may review and reappreciate the evidence, but must respect the double presumption of innocence and should not interfere where the trial court’s view is a reasonable and possible one; interference is justified only where the judgment is perverse, patently illegal, wholly untenable, or results from a serious misreading of the evidence.

This principle was drawn from Bannareddy v. State of Karnataka, (2018) 5 SCC 790; Jayamma v. State of Karnataka, (2021) 6 SCC 213; Babu v. State of Kerala, (2010) 9 SCC 189; Chandrappa v. State of Karnataka, (2007) 4 SCC 415; Ghurey Lal v. State of Uttar Pradesh, (2008) 10 SCC 450; Ramesh Babulal Doshi v. State of Gujarat, (1996) 9 SCC 225; and Rajesh Prasad v. State of Bihar, (2022) 3 SCC 471.

In a case based on circumstantial evidence, the prosecution must establish a complete and unbroken chain of circumstances pointing exclusively to the guilt of the accused, consistent with the principles in Hanumant Govind Nargundkar v. State of M.P., 1952 SCC OnLine SC 75, and Sharad Birdhichand Sarda v. State of Maharashtra, (1984) 4 SCC 116.

The Court held that the prosecution case rested entirely on circumstantial evidence and contained no eyewitness account or reliable last-seen evidence linking Ramgulam with Rambhajan.

The Investigating Officer admitted that no witness had stated during investigation that the deceased was last seen with the accused, or that the accused had committed the murder or thrown the body into the drain.

The identification of the deceased was also doubtful: the body recovered on 20 March 2012 was highly decomposed, no clothes or socks were found with it, and the family members neither saw nor identified the body at the time of recovery or post-mortem.

Their later claim, made nearly four months afterward, rested only on a pair of socks allegedly found near the drain, which did not reliably establish either the identity of the deceased or the accused’s involvement.

Applying the principles governing circumstantial evidence and appellate restraint in acquittal appeals, the Court found the trial court’s assessment reasonable and plausible rather than perverse or legally unsustainable.

It held that the prosecution failed to prove the identity of the deceased and failed to establish a complete chain of circumstances connecting Ramgulam with the murder or concealment of evidence beyond reasonable doubt.

The trial court’s acquittal was a possible and properly reasoned view of the evidence and did not warrant appellate interference.

Accordingly, the government appeal was dismissed and Ramgulam’s acquittal was affirmed.