The Supreme Court of India revisited a Karnataka murder case based entirely on circumstantial evidence and granted relief to two co-accused. The Court closely examined whether the chain of evidence was complete enough to sustain conviction..
Background of the Case
The case arose from the disappearance of a woman in March 2013. Her charred skeletal remains were later recovered from a forest area. The prosecution alleged that the accused abducted, murdered, and burned the body to destroy evidence.
The trial court convicted all accused under serious offences including murder, abduction, and destruction of evidence. The Karnataka High Court upheld this conviction, relying on circumstantial evidence such as last seen theory, recovery of objects, and alleged motive.
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According to the prosecution, the deceased was last seen in the company of the main accused and others. It was further alleged that:
- There was a financial dispute involving ₹20 lakh and gold ornaments.
- The accused were seen together shortly before the disappearance.
- Recovery of items like a car, rope, petrol container, and jewellery linked the accused to the crime.
The prosecution argued that these circumstances formed a complete chain pointing to guilt.
The co-accused challenged the conviction, arguing:
- There was no direct evidence connecting them to the crime.
- No clear motive was attributed to them.
- The “last seen” evidence was weak and unsupported by proper identification procedures.
- Recoveries were made only at the instance of the main accused, not them.
The bench, led by Justice J.B. Pardiwala, emphasized the strict standards required in cases based on circumstantial evidence.
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The Court noted that:
- “The entire case of the prosecution hinges on circumstantial evidence.”
- The “last seen” theory alone is insufficient unless supported by strong corroboration.
- There was no clear motive established against the appellants.
- Most recoveries were linked only to the primary accused.
On the issue of last seen evidence, the Court observed that relying solely on such testimony would be risky without additional supporting material.
The bench further highlighted that the chain of evidence must be complete and must exclude every other reasonable hypothesis.
After evaluating the evidence, the Supreme Court found that the prosecution failed to establish a complete and unbroken chain of circumstances against the co-accused.
The Court held that the evidence was insufficient to prove their role as accomplices beyond reasonable doubt. Accordingly, the appeals were allowed, and relief was granted to the appellants.
Case Details
Case Title: Anand Jakkappa Pujari @ Gaddadar v. State of Karnataka & connected matter
Case Number: Criminal Appeal No. 1864 of 2024 & Criminal Appeal No. 2180 of 2026
Judge: Justice J.B. Pardiwala and Justice K. V. Viswanathan
Decision Date: 27th April, 2026
