Failure to establish a complete chain of circumstantial evidence excluding alternative hypotheses mandates acquittal.

The appellant was convicted of murder under Section 302 IPC by the II Additional Session Judge, Jabalpur, in S.T No. 394/2014, following the death of his wife.

The prosecution alleged the appellant strangled the deceased and hanged her body in a room to simulate suicide.

The Investigating Officer (PW-9) admitted that upon reaching the scene, the room was locked from both sides, necessitating the removal of roof sheets (secured by nut-bolts) to gain entry.

The prosecution argued a one-foot gap between the wall and the roof allowed the appellant to escape after the act.

The medical expert (PW-8) initially termed the death homicidal based on ligature marks and a burst trachea but admitted in cross-examination that such injuries could occur during an attempted suicide or the transportation of the body.

1. Whether the prosecution successfully established a complete chain of circumstantial evidence to prove the death was homicidal and caused by the appellant.

2. Whether the trial court erred in convicting the appellant despite evidence indicating the room was inaccessible and locked from the inside.

The court primarily applied Section 302 of the Indian Penal Code regarding murder.

Evidentiary standards for circumstantial evidence established in Jagdish Gond v. State of Chhattisgarh (2025 SCC OnLine 744), which requires a chain of circumstances so complete that it excludes every hypothesis except the guilt of the accused.

State of U.P. v. Anil Singh (AIR 1998 SC 1998) regarding the duty of the court to ensure the guilty are punished while the innocent receive the benefit of the doubt.

The High Court found that the prosecution failed to bridge the gap between "may be" and "must be." The court observed that the Investigating Officer (PW-9) provided no documentary evidence or measurements regarding the alleged one-foot gap through which the appellant supposedly escaped.

The fact that the police had to dismantle the roof to enter the room strongly suggested the room was locked from the inside, supporting the theory of suicide.

The medical evidence was deemed inconclusive, as PW-8 admitted that the abrasions and internal injuries were consistent with a person struggling to get rid of a noose during a suicide attempt.

The court criticized the trial court for viewing the case with a "jaundiced eye" and relying on the oral testimony of the I.O. without investigative support, noting that the chain of circumstances was entirely incomplete.

The appeal was allowed, and the appellant was acquitted.

The Court further ordered the State to pay the appellant Rs. 50,000 in costs/compensation, to be invested in a monthly income scheme for his rehabilitation following his long incarceration.