Recently, the Supreme Court upheld the conviction of an accused in a murder case, stressing that the prosecution's failure to prove sole motive based on circumstantial specificity is not a cause of death.
The judgment delivered by a bench of Surya Kant and N. Kotiswar Singh involved a case in which the appellant was convicted for murder. The conviction was based primarily on circumstantial reflections, including the "last seen" theory, recovery of the murder weapon and empty rats and other evidence-related to the 100-000 murder.
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The appellant argued that the prosecution's failure to prove any motive cannot lead to conviction. On the other hand, the prosecution said that the reason cited by the accused for the murder of the deceased was a financial dispute, where the deceased allegedly failed to repay a loan of ₹4,000 and insulted the accused when he asked for the money.
The Supreme Court clarified that even if the motive is not established, the conviction can still be sustained if circumstantial reflections reveal a complete and cogent pattern of evidence pointing to the guilt of the accused.
"This law does not require that all doubts on any fact be proven. What is required is to eliminate the doubt - not any speculative, imaginary or fictitious doubt, but the doubt based on reason and common sense," the Court said.
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"This should lead to the guilt of the accused, the protection effect of all Poland, clearly. Although one circumstance is not stable in itself, when it is combined with others, guilt can be established," the Court clarified.
The judgment also stated that it is difficult to characterize the motive because the character is hidden in the mind. In many cases, the motive must be inferred from conduct and indignation rather than direct evidence.
"The law is well established that evidence of motive certainly strengthens the prosecution's case based on circumstantial reflection, but failure to prove it may not be fatal," the court said quoting G. Parshwanath vs State of Karnataka (2010).
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The case was further strengthened by archaeological investigations and ballistic scientists finding that the remains and the packets containing the deceased's brain matched those recovered from the appellant's house, where the murder weapon was also found. This evidence, along with corroborating witnesses' testimony, built a strong case against the accused.
"The connection to the appellant was further deepened through forensic and ballistic analysts. The recovered weapon, its composition levels and the mail crate created a compelling narrative along the timeline of the crime," the court said.
Another important theory was that Abbas had tried to prove the crime by telling Shailesh Sadhi. The court said that the prosecution's evidence was based on evidence, but no assurance was given about the recovery of the weapon and the case became strong.
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The court concluded, "The onus was on the appellant to explain the crime against the recovery of the weapon, which was linked to the injury inflicted by the deceased. The failure to explain the guilt-proving evidence produced by Sheila Shails and her makes the prosecution's case strong."
Case Title: CHETAN VERSUS THE STATE OF KARNATAKA
Appearance:
For Appellant(s) : Mr. D.N.Goburdhun, Sr. Adv. Mrs. Rajani K Prasad, Adv. Ms. Abha R. Sharma, AOR
For Respondent(s) : Mr. Muhammad Ali Khan, A.A.G. Ms. Eesha Bakshi, Adv. Mr. Prashant Pratap Singh, Adv. Mr. Kamran Khan, Adv. Mr. V. N. Raghupathy, AOR
