Supreme Court Clears Chhattisgarh Man of Murder, Says 'Last Seen' Evidence Alone Can't Send Someone to Jail for Life

By Shivam Y. • December 19, 2025

Manoj @ Munna vs. State of Chhattisgarh, Supreme Court acquits Manoj alias Munna in Chhattisgarh murder case, ruling that ‘last seen together’ evidence alone cannot justify a life sentence.

The Supreme Court on Wednesday brought an end to a long-running murder case from Chhattisgarh, acquitting Manoj alias Munna after nearly two decades of legal back-and-forth. Sitting in a packed courtroom, the bench made it clear that suspicion, however strong, cannot replace solid proof. The appeal arose from a 2011 High Court ruling that had upheld his life sentence for murder and destruction of evidence.

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Background

The case goes back to June 2004. Yuvraj Singh Patle, a tractor driver, was found dead with burn injuries. The prosecution story was that Manoj, along with others, had taken Patle away on the pretext of work and later killed him, allegedly to rob a tractor and arrange money.

The trial court believed this version, relying mainly on witnesses who claimed that the accused was “last seen” with the deceased. While five co-accused were acquitted, Manoj was convicted under Sections 302 and 201 of the IPC and sentenced to life imprisonment. The High Court later agreed with that view.

Court’s Observations

Before the Supreme Court, the focus narrowed to one key question: can a person be convicted only because he was last seen with the deceased?

Justice Prashant Kumar Mishra, speaking for the bench, reminded that this was a case based entirely on circumstantial evidence. The Court accepted that the death was homicidal, as medical evidence showed serious burn injuries. But that alone was not enough.

“The bench observed, ‘In cases resting on circumstantial evidence, the chain must be complete and point only towards guilt.’” The judges noted that the alleged motive-robbing the tractor to raise money-was not convincingly proved. There was no clear evidence that the tractor was sold or even attempted to be sold.

On the “last seen” theory, the Court said it is a weak link by itself. Unless the time gap between the last sighting and the death is so small that no other possibility exists, a conviction cannot rest on that fact alone. The judges also clarified that an accused’s silence or failure to explain events cannot cure gaps in the prosecution’s case.

Decision

In the end, the Court held that the evidence raised doubts but did not cross the line into certainty. Giving Manoj the benefit of doubt, the bench set aside the convictions recorded by both the trial court and the High Court.

“The appeal is allowed,” the Court ordered, acquitting Manoj of all charges and discharging his bail bonds.

Case Title: Manoj @ Munna vs. State of Chhattisgarh

Case No.: Criminal Appeal No. 1129 of 2013

Case Type: Criminal Appeal (Murder & Destruction of Evidence)

Decision Date: December 18, 2025

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