Supreme Court acquits an accused as there were no eyewitnesses to the incident

The present appeal arose when the trial court convicted the appellant, Hansraj, for the offence under Section 302 of the Indian Penal Code (IPC), for the murder of Ramlal. The order of the Trial Court sentencing Hansraj to life imprisonment and a fine was upheld by the High Court. The prosecution's case was based on circumstantial evidence as there were no witnesses to the crime.

The Supreme Court entertained an appeal by Hansraj, who was convicted of murdering Ramlal. The prosecution relied on circumstantial evidence in the case against the prosecution, and it was contended that Hansraj was seen running away from the crime scene when Ramlal was discovered dead. The Supreme Court allowed the appeal, acquitting Hansraj of all charges since it ruled that the circumstantial evidence was not sufficient to prove his guilt beyond a reasonable doubt. The court referred to discrepancies in the testimonies of witnesses and the lack of concrete evidence linking Hansraj to the crime.

Rules of Circumstantial Evidence: The five golden rules (panchsheel) for circumstantial evidence cases as enunciated in Sharad Birdhichand Sarda vs State of Maharashtra were followed by the court. These five rules stipulate that circumstances must be proved beyond a doubt, in accordance with guilt, conclusive, exclude every hypothesis except the one of the guilt of the accused, and chain of evidence.

Doubtful Motive: Non-payment or delayed payment of wages, as attributed to him, was deemed to be lacking and insignificant to initiate such a grave offense. The court noted the lack of cogent proof to show any difference of opinion between Hansraj and the deceased.

Last Seen Theory Suspicion: The court cast suspicion on the "last seen theory," since evidence of Hansraj's visit to the deceased's house after he had initially proceeded to his hometown was not corroborated independently. Failure to corroborate whether the cycle was actually punctured tended to weaken the prosecution case.

As far the recovery of the farsi (weapon) is concern, the Supreme Court was doubful with inconsistencies in the evidence of its discovery. The absence of a forensic report to compare the blood stains on the farsi with the deceased's blood further questioned its credibility as the weapon of crime.

The Apex Court noticed the contradictions among the depositions of the star witnesses. The witness Budhiyarin Bai (PW-5) and Jogi Ram (PW-1) version created suspicion regarding the statement that Hansraj was clearly seen running away from the place of occurrence.

The Apex Court also observed that the prosecution was unable to bring a forensic report linking the blood stains on the clothes of the appellant with the blood of the deceased was the weakest aspect in the prosecution case.

In conclusion, the Supreme Court ruled that as per the facts of the case the prosecution failed to prove Hansraj's guilt beyond reasonable doubt and, as such, entitled to the benefit of the doubt.

The Supreme Court allowed the appeal, setting aside the judgments of the Courts below and acquitting Hansraj of murder. The court directed his bail bonds to be released, noting his incarceration for over 10 years.

Coram: Justice Pankaj Mithal and Justice Ahsanudding Amanullah
Case: Hansraj vs State of Chhattisgarh
Judgment Date: 10-02-2025