The Supreme Court acquitted Manoj alias Munna in a 2004 Chhattisgarh murder case, holding that suspicion cannot replace proof. The Court ruled that “last seen” evidence alone is too weak to justify a life imprisonment conviction.
New Delhi: The Supreme Court on Wednesday finally closed a murder case from Chhattisgarh that had continued for almost 20 years, by acquitting Manoj alias Munna. The Court made it very clear that even strong suspicion cannot take the place of clear and reliable proof in a criminal trial.
The appeal before the Court challenged a 2011 judgment of the Chhattisgarh High Court, which had confirmed Manoj’s conviction and life sentence for murder and destruction of evidence.
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The case dates back to June 2004. Yuvraj Singh Patle, who worked as a tractor driver, was found dead with severe burn injuries. The prosecution claimed that Manoj, along with other accused persons, had taken Patle away on the excuse of work.
According to the prosecution, Patle was later killed so that his tractor could be robbed and money could be arranged from it.
During the trial, the prosecution relied mainly on witnesses who stated that Manoj was “last seen” with the deceased before his death.
The trial court accepted this version. Although five other accused were acquitted due to lack of evidence, Manoj was convicted under Sections 302 and 201 of the Indian Penal Code and sentenced to life imprisonment. This conviction was later upheld by the High Court, which agreed with the trial court’s reasoning.
When the matter reached the Supreme Court, the case was examined closely from the point of view of circumstantial evidence. The main issue before the Court was whether a conviction could be sustained only on the basis that the accused was last seen with the deceased.
Justice Prashant Kumar Mishra, speaking for the Bench, observed that the entire case was based on circumstantial evidence.
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The Court accepted that the death was homicidal in nature, as the medical records clearly showed serious burn injuries. However, the judges stressed that this fact alone could not justify a conviction unless the rest of the evidence formed a complete and unbroken chain.
The Bench observed,
“In cases resting on circumstantial evidence, the chain must be complete and point only towards guilt.”
The Court found that this requirement was not satisfied in the present case. The alleged motive, which was said to be robbing the tractor to raise money, was also not properly proved. There was no reliable evidence to show that the tractor was actually sold or that any serious attempt was made to sell it.
On the issue of the “last seen” theory, the Supreme Court explained that it is a weak piece of evidence if it stands alone.
The Court said that unless the time gap between the last time the accused and the deceased were seen together and the time of death is very small, and unless no other possibility can exist, a conviction cannot be based only on this circumstance.
The judges also clarified that an accused person’s silence or failure to explain certain facts cannot be used to fill the gaps left by the prosecution.
After examining the entire record, the Supreme Court concluded that while the evidence raised suspicion against Manoj, it did not prove his guilt beyond reasonable doubt. Since criminal law requires certainty and not mere suspicion, the Court decided to give Manoj the benefit of doubt.
Accordingly, the Bench set aside the judgments of both the trial court and the High Court. “The appeal is allowed,” the Court ordered, acquitting Manoj of all charges. His bail bonds were also discharged.
Case Title:
Manoj @ Munna vs. State of Chhattisgarh
Criminal Appeal No. 1129 of 2013.
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