An incomplete circumstantial-evidence chain cannot sustain a murder conviction.

The appellant was convicted under Section 302 of the Indian Penal Code (IPC) for allegedly murdering Sukanya @ Indira by slitting her neck and taking her jewellery.

The prosecution relied on circumstantial evidence, including their alleged prior acquaintance and cohabitation, recovery of jewellery and clothing, the alleged purchase and recovery of a knife, and the homicidal death.

The Sessions Court convicted the appellant and sentenced him to life imprisonment and a fine. He appealed under Section 374(2) of the Code of Criminal Procedure.

The High Court considered the evidence concerning the deceased’s identification and death, the alleged association between her and the appellant, and the disputed recoveries.

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

Whether the alleged recoveries of the deceased’s jewellery and clothing, the appellant’s bloodstained clothes, and the knife reliably connected the appellant to the offence.

The appellant was charged and convicted under Section 302 IPC for murder.

In a case resting on circumstantial evidence, the prosecution must establish the circumstances and a complete chain beyond reasonable doubt; the circumstances must support the conclusion that the accused committed the offence. Where the chain is incomplete or the evidence leaves reasonable doubt, the accused is entitled to the benefit of that doubt.

The Court accepted that the death was homicidal, but held that the evidence did not establish that the deceased left her home with the appellant or was later seen with him; the landlord’s evidence did not support the alleged cohabitation.

The recovery evidence was also doubtful: the husband’s account suggested that the appellant and the jewellery were already at the police station on 2 February, although the prosecution claimed the appellant was arrested on 4 February and the jewellery recovered later; the panch witnesses did not consistently support the recoveries, and the accounts of the knife’s location and production conflicted.

Because the recoveries were not reliable, the Court found that the FSL result concerning the appellant’s clothes could not cure the defects in proof of seizure.

The circumstances, taken together, therefore did not form a complete chain.

It directed that he be released forthwith unless required in another case.