Supreme Court Sets Aside Conviction in Constable Murder Case Due to Weak Circumstantial Evidence

Appellant, Murugan, challenged the Madras High Court's judgment, which had partly allowed the appeal by acquitting him of the offence under Section 148 of the Indian Penal Code (IPC) but sustained his conviction and sentence of life imprisonment for the murder of a Special Branch Grade-I Constable, Jagadeesh Durai.

The prosecution's case was that the deceased constable was chasing the appellant and two others who were illegally transporting sand when he was fatally attacked him which resulted in his death. The Trial Court had convicted Murugan and another accused under Sections 148 and 302 IPC, while acquitting one accused and convicting others under different charges which were later overturned by the High Court.

The question before the Apex Court was whether the prosecution had established the guilt of the appellant beyond a reasonable doubt, relying primarily on circumstantial evidence, after the High Court had disbelieved the testimony of the alleged eyewitness and found the extra-judicial confessions of co-accused inadmissible.

Supreme Court observed that with the rejection of key prosecution witnesses, including the alleged eyewitness (PW2) whose presence at the crime scene was deemed impractical and his conduct inconsistent, and the last seen witness (PW12) whose testimony suffered from a significant unexplained delay in reporting to the police, the remaining evidence was insufficient to conclusively establish the appellant's guilt.

The Apex Court also reiterated the established principles for cases based on circumstantial evidence, emphasizing that the chain of events must be so complete that it leads to only one conclusion – the guilt of the accused, leaving no room for any other reasonable hypothesis consistent with their innocence. The Court also noted the unexplained delay in presenting the First Information Report (FIR) to the Magistrate.

The Apex Court held that with the primary evidence discarded, the remaining circumstantial evidence, consisting mainly of the recovery of a wheel spanner (alleged weapon) with the appellant's fingerprints and the presence of three pairs of slippers at the crime scene, was not sufficient to unequivocally establish the appellant's involvement in the murder. Consequently, the appellant was ordered to be released forthwith if not required in any other case.

Thus, Supreme Court allowed the appeal and set aside the conviction and sentence passed by the Trial Court and which was upheld by the High Court.

CORAM: JUSTICE ABHAY S. OKA, JUSTICE AHSANUDDIN AMANULLAH & JUSTICE AUGUSTINE GEORGE MASIH
BETWEEN: MURUGAN VS THE STATE OF TAMILNADU REP. BY THE INSPECTOR OF POLICE 2025 INSC 446
DATE OF JUDGMENT: 04-04-2025