Supreme Court Overturns Murder Conviction Due to Broken Chain of Circumstantial Evidence Flawed Identification and Inconclusive DNA

In a case involving a murder of a ten year old boy, the Supreme Court of India overturned the conviction and sentence imposed upon the three appellants for the murder of a ten-year-old boy.

The Trial Court and the High Court had convicted the appellants under Sections 302, 201, and 120-B of the IPC on charges of a ten year old boy named Muntiyaz Ali in June 2007, whose body was discovered strangled with a rope, having been killed following his disappearance from a family orchard. The Trial Court relyied entirely on circumstantial evidence presented through prosecution witnesses (PW-2, PW-3, and PW-4) and the High Court of Uttarakhand at Nainital upheld the conviction, However, the Supreme Court concluded that the prosecution failed to establish a complete and unbroken chain of circumstances consistent only with the appellants’ guilt, necessitating their acquittal.

The Apex Court rigorously tested the evidence against the panchsheel (five golden principles) governing circumstantial cases. The judges made several critical observations that collectively broke the chain of proof:

-The Apex Court on the unreliable testimony of PW-2, who claimed to have overheard the murder conspiracy, held that it was deemed improbable and unreliable, particularly because he suppressed this crucial information from the complainant and omitted it from the FIR he himself scribed, explaining his silence merely as treating the matter as "loose talk" due to pre-existing enmity.

-The 'last-seen' theory based on the witnesses (PW-3 and PW-4) were appeared to be unreliable to the Apex Court as PW-3 admitted he did not know the accused previously, yet no Test Identification Parade (TIP) was conducted. The time gap between the alleged sightings (morning/evening of June 5, 2007) and the discovery of the body (morning of June 6, 2007) was too wide to exclude the possibility of intervention by a third party.

-The Apex Court found the Forensic Science Laboratory (FSL) report as neutral for failing to generate a complete DNA profile from the recovered exhibits (axe, rope) and thus the Court held that I neither connected the Appellants to the crime nor corroborated the oral testimony. The Court held that relying on doubtful testimony while ignoring neutral scientific findings is substituting suspicion for proof.

Citing the judgment in case of Kali Ram v. State of Himachal Pradesh, 1973 -Click to Download- ** held that "where the evidence admits two possibilities, i.e. one pointing to guilt and the other to innocence then the accused must receive the benefit of doubt.", thus, the Apex Court observed that the there is a posibility which is pointing to innocence must and the accused must receive the benefit of doubt.

Ultimately, the Supreme Court found that the prosecution had failed fundamentally to establish a complete and unbroken chain of circumstances, concluding that the evidence on record was not consistent only with the hypothesis of the accused’s guilt, and the appellants were entitled to the benefit of the doubt. Accordingly, the appellants were acquitted of all charges.

Coram: Justice M. M. Sundresh and Justice Satish Chandra Sharma.