The Supreme Court of India has reaffirmed a fundamental principle of criminal law while acquitting two individuals previously convicted of murder. The court ruled that Section 27 of the Indian Evidence Act cannot be used to support the prosecution unless it is conclusively established that a discovery was made based on the accused’s disclosure. This ruling serves as a vital reminder that circumstantial evidence must be firmly linked to the accused beyond all reasonable doubt.
“If that be the position, not only the chain of circumstantial evidence is not complete, all the circumstances put forth by the prosecution to prove the guilt of the appellant cannot be accepted as having been proved as valid pieces of evidence. Therefore, the appellant deserves to be given the benefit of doubt and is entitled to an acquittal on this count,” observed the Bench of Justices Abhay S. Oka and Ujjal Bhuyan.
Section 27 of the Evidence Act stipulates that information provided by an accused while in police custody can only be admitted as evidence if it distinctly relates to a fact that is subsequently discovered. The Supreme Court reiterated that unless a recovery is unequivocally tied to the accused’s disclosure, the evidence cannot be admissible under this section. The court relied on precedents such as Pulukuri Kottaya vs. King-Emperor, which emphasized the necessity of establishing a clear link between the accused's knowledge and the discovered fact.
Read Also:- Supreme Court Acquits Murder Accused Extrajudicial Confession Lacked Credibility
Case Background
The case arose from an FIR filed by the deceased’s father, who alleged that the appellant had kidnapped his minor daughter. The prosecution's case rested on three key factors: the accused being last seen with the victim, an extrajudicial confession, and the recovery of the body following statements made by the accused. While the High Court dismissed the extrajudicial confession for being made in police presence, it upheld the conviction based on the remaining two factors. However, the Supreme Court found that this was insufficient to establish guilt beyond reasonable doubt.
The Supreme Court identified multiple flaws in the prosecution’s case, including contradictory witness statements, the absence of motive, and inconsistencies in the alleged sequence of events. Additionally, the court noted that while circumstantial evidence is admissible, it must form an unbroken chain that leads exclusively to the conclusion of guilt. Any gap in this chain entitles the accused to the benefit of doubt.
“When one of the three circumstances was disbelieved and discarded by the High Court, then the chain of circumstantial evidence could not have been held to be complete and proved and on that basis to hold the accused guilty of the offence. Each and every circumstance forming the chain of circumstantial evidence has to be proved,” the court ruled.
Read Also:- Strong Suspicion Alone Is Not Enough: Supreme Court Acquits Defendant in Murder Case Due to Lack of Evidence
In its final verdict, the Supreme Court overturned the lower court’s decision and acquitted the accused, concluding that the prosecution had failed to conclusively establish the accused’s guilt.
“When the prosecution failed to prove each of the circumstances against the appellant, the courts below were not justified in convicting the appellant.”
This ruling underscores the need for strong, direct evidence in criminal convictions. It serves as a crucial precedent to prevent convictions based on speculative or incomplete circumstantial evidence. By reinforcing the importance of adhering to the principles of criminal justice, the Supreme Court ensures that the rule of law is upheld.
Case Name: MD. BANI ALAM MAZID @ DHAN v. STATE OF ASSAM (Criminal Appeal No. 1649 of 2011)
