The Supreme Court ruled that a accused cannot be convicted based solely on circumstantial evidence. It further stated that the present matter was clearly a case built entirely on circumstantial evidence.
New Delhi: In a landmark decision, the Supreme Court recently set-aside a judgment from the Chhattisgarh High Court that had convicted a man for murder and other offenses, stating that an accused cannot be found guilty in a case based solely on circumstantial evidence.
The apex court granted the appeal of the accused-appellant, Firuram Sahu, acquitting him of all charges.
A two-judge bench comprising Justice Sudhanshu Dhulia and Justice K Vinod Chandran in their recent ruling, asserted,
“There is absolutely no chain of circumstances available in the case which could lead to a conclusion of guilt, and there remains considerable scope for alternative hypotheses pointing to the innocence of the accused (Firuram Sahu),”
By setting aside the High Court’s decision, the Supreme Court dismissed the prosecution’s case as unreliable. Sahu’s counsel and Advocate-on-Record (AOR), Hitendra Rath, noted that the top court did not accept the prosecution’s account.
The court emphasized that this was a clear case of circumstantial evidence. The prosecution’s only claim was a land dispute between the deceased and the accused. The deceased’s son testified that his mother had expressed concerns about the accused on the day of the murder.
However, the court rejected the testimonies of the prosecution witnesses, including the deceased’s son, reaffirming that no definitive chain of events was established to prove guilt beyond a reasonable doubt.
The court stated,
“It is evident that the circumstances proved relate only to a title dispute between the deceased and the appellant, and the recovery of a ‘tessi’ with human blood from the appellant’s bathroom following a disclosure allegedly made by him. However, this recovery alone is not sufficient to convict the accused of murder,”
The court further noted that the prosecution failed to present any credible evidence directly linking the accused to the crime.
The court added,
“The recovery is inconsequential, as the alleged weapon was never conclusively connected to the murder,”
Consequently, the court concluded that the prosecution had not proven its case beyond reasonable doubt.
The apex court ruled,
“Under these circumstances, the conviction and sentence of the appellant are set aside,”
Firuram Sahu had been convicted under multiple sections of the Indian Penal Code (IPC), including Section 302 (Murder) and Section 201 (Destruction of Evidence), and sentenced to life imprisonment by the trial court.
This conviction was upheld by the Chhattisgarh High Court in 2024, leading Sahu to challenge it in the Supreme Court.
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