Supreme Court Reiterates Five Principles of Circumstantial Evidence

The present appeal in case of Ravi vs The State of Punjab, arises out of the conviction of the appellant Ravi by trial courts for having murdered his first wife Jamni by strangulation. The offense was committed on August 22, 2014, at the village Madh, Amritsar, where Ravi resided along with Jamni, his second wife Soma, and his two sons from his previous marriage. The case of the prosecution was circumstantial, stating that Ravi, assisted by Soma, killed Jamni and took her body to her brother's village.

The Supreme Court heard an appeal by Ravi against his conviction for murder of his wife, Jamni.

The case of the prosecution was based on circumstantial evidence, and the brother of the deceased filed a Zero FIR that Ravi killed Jamni by strangulation with the assistance of his second wife, Soma. In spite of the FIR and post-mortem reports of death by asphyxia by hanging and ligature marks on the neck, the main witnesses, the deceased's brother and sister, became hostile and stated that Jamni had died of illness.

The Supreme Court granted the appeal, quashing the conviction, and held that the prosecution was unable to establish the guilt of Ravi beyond reasonable doubt on the basis of circumstantial evidence adduced.

Significant Observations Made By The Apex Court:

Hostile Witnesses: The Apex Court observed that the major witnesses, the brother and sister of the deceased, were rendered hostile, weakening the case of the prosecution.

Inconclusive Medical Evidence: The Court noted that the post-mortem report's asphyxia findings could be due to chronic tuberculosis or movement of the body, diluting the prosecution's argument of murder by strangulation.

Weakness of Circumstantial Evidence: The court laid stress on the fact that circumstantial evidence was not conclusive enough to prove Ravi's guilt and left scope for conflicting opinions, hence compelling the benefit of doubt to be accorded to the appellant.

Section 106 of the Evidence Act: The court interpreted that Section 106 of the Evidence Act, which puts a burden on the accused to account for facts entirely within their personal knowledge, takes effect only upon the establishment by the prosecution of a prima facie case.

Statement Under Section 313 CrPC: The court noted the appellant's statement under Section 313 of the Code of Criminal Procedure, where he claimed the deceased died of chronic tuberculosis and was undergoing treatment, which the prosecution failed to investigate.

Principles of Circumstantial Evidence: The Apex Court relied on the five principles of circumstantial evidence established in Sharad Birdhichand Sarda v. State of Maharashtra (Click to Download), noting that the circumstances should clearly prove guilt, rule out other possibilities, and create a chain of evidence.

The Supreme Court granted the appeal, quashed the High Court's judgment, and ordered Ravi to be released from detention since the prosecution could not establish his guilt beyond reasonable doubt.

Coram: Justice Pankaj Mithal and Justice Ahsanuddin Amanullah
Case: Ravi vs The State of Punjab
Judgment Date: 10-02-2025