In a significant ruling, the Gujarat High Court set aside the conviction and death sentence of a man accused of a brutal double murder, holding that the prosecution failed to establish a complete chain of circumstances proving guilt beyond reasonable doubt.
Background of the Case
The case, titled State of Gujarat vs. Baldevbhai Budhaji Dhulaji Chauhan (Thakor), arose from a 2017 incident in Ahmedabad where a mother and her son were found dead inside their home.
The trial court had convicted the accused under Sections 302 (murder) and 201 (destruction of evidence) of the Indian Penal Code and awarded capital punishment. The matter reached the High Court through a criminal appeal and a death sentence confirmation reference.
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According to the prosecution, the accused allegedly killed both victims with an axe following a personal dispute and later attempted to destroy evidence by cleaning the scene and disposing of materials.
The Division Bench of Justice Ilesh J. Vora and Justice R.T. Vachhani closely examined the evidence and noted that the entire case rested on circumstantial evidence, with no eyewitness to the incident.
The Court reiterated the settled legal principle that in such cases,
“the chain of circumstances must be complete and must point only towards the guilt of the accused.”
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However, the bench found several critical gaps:
- Key witnesses, including neighbours and panch witnesses, turned hostile and did not support the prosecution.
- The alleged “last seen” evidence was not proved in court.
- The recovery of weapons and clothes was not established in accordance with law.
- CCTV footage lacked the mandatory legal certification required for admissibility.
On the issue of confession during reconstruction of the crime scene, the Court made it clear:
“A confession made to police cannot be treated as admissible evidence,” noting that such material is barred under the Evidence Act.
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The bench also observed that reliance on police statements recorded during investigation, without proper courtroom testimony, cannot form the basis of conviction.
Breakdown in Evidence Chain
The Court emphasized that suspicion, however strong, cannot replace proof.
It noted that:
- Motive was not convincingly established.
- The prosecution failed to link the accused to the crime through reliable and consistent evidence.
- The chain of circumstances remained incomplete, leaving room for doubt.
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The judges remarked that the case failed to move from “may be true” to “must be true,” a crucial standard in criminal law.
After evaluating the evidence, the Gujarat High Court held that the prosecution had not proved the case beyond reasonable doubt.
The Court allowed the appeal, set aside the conviction and sentence, and declined to confirm the death penalty awarded by the trial court.
Case Details:
Case Title: State of Gujarat vs. Baldevbhai Budhaji Dhulaji Chauhan (Thakor)
Case Number: Criminal Confirmation Case No. 2 of 2024 with Criminal Appeal No. 2812 of 2024
Judges: Justice Ilesh J. Vora & Justice R.T. Vachhani
Decision Date: 10 April 2026
