The Supreme Court held that circumstantial evidence can justify a conviction only when it is completely inconsistent with the accused’s innocence. The Court ruled that conviction cannot be based solely on the “last seen together” theory without strong corroborative proof.
New Delhi: The Supreme Court on Thursday clearly explained how circumstantial evidence should be used in criminal cases and said that a person can be convicted only when such evidence points only towards guilt and not towards innocence.
While setting aside the conviction and life sentence of a man accused in a 2004 murder case, the Supreme Court said that the “last seen together” theory by itself is not enough to convict someone when the case is based entirely on circumstantial evidence.
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The judgment was delivered by a Bench of Justice Sanjay Karol and Justice Prashant Kumar Mishra.
Justice Mishra, who wrote the judgment, restated an important principle of criminal law and said,
“It is a well-established rule in criminal jurisprudence that circumstantial evidence can be made the basis of the conviction of an accused person if it is of such a character that it is wholly inconsistent with the innocence of the accused and is consistent only with his guilt,”
The Court explained that when there is no direct evidence like eyewitness testimony, the circumstances relied upon by the prosecution must be very strong. These circumstances must point only towards the guilt of the accused and must rule out every other possible explanation that suggests innocence.
The judgment further said,
“And if the circumstances proved against the accused, in a particular case, are consistent with the innocence of the accused, he will be entitled to the benefit of the doubt,”
Giving relief to the accused, the Bench acquitted Manoj alias Munna, after finding serious gaps and missing links in the prosecution’s chain of evidence. The Court said the evidence brought on record was not strong enough to conclusively prove that Manoj alone had committed the crime.
Referring to the facts of the case, the Supreme Court observed,
“We are of the opinion that the nature of circumstantial evidence available against the appellant though raises a doubt that he may have committed the offence but the same is not so conclusive that he can be convicted only on the evidence of the last seen together (theory).”
The Court once again underlined a settled principle of law and said that whenever there is any doubt in the mind of the court, such doubt must always benefit the accused and not the prosecution.
The judgment further stated,
“The present case is one where except for the evidence of last seen together, there is no other corroborative evidence against the appellant. Therefore, the conviction only on the basis of last seen together cannot be sustained,”
On this basis, the Supreme Court set aside the earlier judgments passed by the trial court and the High Court.
The case goes back to June 2004, when the prosecution alleged that Manoj, along with five other accused persons, had murdered Yuvraj Singh Patle, a tractor driver, with the intention of stealing the tractor and selling it. The deceased was later found with burn injuries and ligature marks on his neck, indicating violence.
During the trial, the court acquitted the five other co-accused. However, Manoj was convicted under Section 302 (murder) and Section 201 (causing disappearance of evidence) of the Indian Penal Code. His conviction was mainly based on witness statements claiming that he was last seen leaving with the deceased on the evening of June 6, 2004.
In 2011, the Chhattisgarh High Court upheld his conviction. However, the Supreme Court found that there was no strong corroborative evidence apart from the “last seen together” theory and held that this alone was insufficient to sustain a conviction.
As a result, Manoj alias Munna was acquitted and granted the benefit of doubt, reinforcing the principle that suspicion, however strong, cannot take the place of proof in criminal law.
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