Incomplete circumstantial evidence cannot sustain conviction unless it excludes every reasonable hypothesis of innocence.

Rubina disappeared on 14 December 2002. Her mother’s missing-person report initially did not name Ramdev; a later complaint alleged that Rubina had left with him. Her body was found on a railway track on 18 January 2003.

The prosecution relied on evidence that Rubina was last seen with Ramdev, marriage-registration proceedings involving Amrit Lal, a handwriting opinion linking Ramdev to a note found near the body, and recovery of Rubina’s belongings from a motorcycle. The trial court convicted Ramdev under Sections 363, 366 and 302 IPC and Amrit Lal under Sections 366 and 368 IPC; the other accused were acquitted. Both appellants appealed.

1. Whether the prosecution proved a complete chain of circumstantial evidence establishing Ramdev’s guilt for kidnapping, abduction and murder

2. Whether the evidence established the victim’s minority and the ingredients of Sections 363 and 366 IPC

3. Whether the prosecution proved that Amrit Lal knowingly concealed or confined a kidnapped or abducted person, as required by Section 368 IPC

4. Whether the handwriting opinion, alleged recovery and other evidence reliably connected Ramdev with the death

Under Sharad Birdhichand Sarda v. State of Maharashtra, a conviction based on circumstantial evidence requires fully established circumstances that form a complete chain, exclude reasonable hypotheses consistent with innocence, and point conclusively to guilt.

The “last seen” circumstance is ordinarily probative where the interval between the accused and deceased being seen together and discovery of the death is sufficiently short to exclude intervention by another person; it cannot, by itself, sustain conviction.

Sections 361 and 363 IPC require proof that a female victim was below eighteen and was taken or enticed from her lawful guardian without consent.

Section 366 requires proof of kidnapping or abduction and the specific intent or knowledge that the woman would be compelled to marry against her will or forced or seduced to illicit intercourse.

Section 368 requires proof that the person was kidnapped or abducted, that the accused knew this, and that the accused then wrongfully concealed or confined that person.

Under Section 27 of the Evidence Act, only the portion of information distinctly related to a discovered fact is admissible.

A handwriting expert’s opinion is admissible but must be assessed cautiously and is not necessarily sufficient, without supporting circumstances, to establish authorship.

The alleged last-seen evidence placed Rubina with Ramdev on 14 December, but her body was recovered more than a month later; the witnesses also gave materially differing accounts of when they disclosed that circumstance, and the prosecution did not account for the intervening period.

The prosecution produced no reliable documentary or medical evidence establishing that Rubina was under eighteen, so the foundational age requirement for Section 363 was not proved.

The sisters’ evidence showed that Rubina left with Ramdev but did not establish force, compulsion or deceit; the marriage-registration documents showed her later appearance with Amrit Lal but did not prove abduction or the specific intent required by Section 366.

The prosecution likewise failed to prove that Amrit Lal knew Rubina had been abducted or that he wrongfully concealed or confined her, as required by Section 368.

The handwriting evidence and alleged note were treated cautiously because of concerns about collection of the specimens and handling of the note; the recovery evidence was weakened by the accessible location and the recovery witness’s evidence that papers had already been prepared.

The alleged confession was not supported by the witness or the village Pradhan, and the medical evidence did not conclusively establish that Rubina had been pushed before a train.

Taken cumulatively, the circumstances did not form a complete chain excluding reasonable doubt.

It allowed both appeals, set aside the convictions and sentences, acquitted Ramdev of the charges under Sections 363, 366 and 302 IPC and Amrit Lal of the charges under Sections 366 and 368 IPC.

Ramdev was ordered released unless required in another case; Amrit Lal was not required to surrender, subject to compliance with Section 437-A CrPC.