Benefit of doubt must be extended where material omissions in previous statements impeach the credibility of eye witnesses.

The appellant was convicted under Section 302 IPC by the Sessions Judge, Dhalai, for the alleged murder of a seven-year-old boy, Kafijoy Tripura, on November 1, 2022.

The prosecution alleged the appellant snatched a dao (takkal) from a witness, dragged the child into a paddy field, and slit his throat.

Following the incident, the appellant was manhandled by a mob before being rescued by security forces and subsequently arrested.

The Trial Court sentenced him to life imprisonment based on the testimonies of 24 witnesses and forensic evidence.

The appellant challenged this conviction on the grounds of material contradictions and lack of scientific proof.

1. Whether the testimonies of the star witnesses (PW-4, PW-5, and PW-11) were reliable enough to sustain a conviction despite significant omissions in their prior statements.

2. Whether the circumstantial and forensic evidence, including DNA profiling and the recovery of the weapon, established the appellant’s guilt beyond reasonable doubt.

The court applied Section 302 of the Indian Penal Code (IPC) regarding the punishment for murder.

It relied on the evidentiary principles concerning "material omissions" in witness statements under Sections 161 and 164 of the CrPC, which can shake the credibility of a witness.

Furthermore, it applied the standard of proof for circumstantial evidence, as established in Anil Shamrao Sute and another v. State of Maharashtra, holding that suspicion, however strong, cannot replace formal proof and that evidence must lead to an irresistible conclusion of guilt.

The High Court found that the prosecution's case was riddled with "vital omissions" that went to the root of the matter.

PW-4 and PW-11 introduced dramatic details in court—such as the appellant snatching the weapon and carrying the dead body—that were entirely absent from their initial statements to the police and the Magistrate.

PW-5, a key eye-witness, was declared hostile and retracted her claims during cross-examination.

Scientifically, the DNA profiling was inconclusive; while human blood was found on a quilt seized from the appellant, the lab could not match it to the deceased’s blood group or DNA profile.

A crucial child witness, Kabita Tripura, was not examined, and no fingerprints were found on the murder weapon.

Consequently, the court determined that the chain of circumstances was broken and the "missing links" failed to connect the appellant to the crime.

It held that the Trial Court had mis-appreciated the evidence and failed to account for the flaws in the prosecution's case.

The High Court set aside the judgment of conviction and sentence dated May 9, 2024.

The appellant was acquitted on the "benefit of doubt," and the court ordered his immediate release from custody.