Wednesday, 27 May 2026

Arrest Memo Mentioned Murder Offence Even Before Body Was Recovered : Supreme Court Upholds Acquittals

 The High Court has, in our considered opinion, rightly

doubted the prosecution case insofar as the alleged recovery of

the dead body at the instance of accused Balraj @ Tiloo is

concerned. The reasons assigned by the High Court are cogent

and borne out from the record. Firstly, because at the time of

arrest of accused Balraj @ Tiloo police was not aware that the

deceased had been killed as PW1 merely filed a missing report,

then how come on the arrest memo filed on the very same date it

was mentioned that the accused was arrested for offence under

Sections 302, 394 and 201 of IPC. Secondly, the testimony of

P.W.5 Basant Singh, an independent witness, materially

undermines the prosecution case. PW5 in his testimony stated

that police had already visited and examined well from where the

dead body was discovered on 28.04.2007 itself, however since the

boring machine was not available, the dead body was recovered

on 29.04.2007. Further P.W.5 stated that none of the accused

people were present on the spot when the recovery was being

made. High Court observed that the Trial Court has totally

ignored the testimony of PW5, which is a crucial piece of evidence as the said testimony challenges the position of the prosecution. Thirdly, the requirement of independent witnesses, more particularly, as per Section 100(4) of Cr.P.C. is to provide

credibility to the investigation. In the present case, admittedly,

the dead body was recovered in the presence of one witness i.e.

P.W. 2 who happens to be uncle of deceased and another person

namely, Ramawtar who has not been produced by the

prosecution for his examination before the Court. {Para 29}

NON-REPORTABLE

IN THE SUPREME COURT OF INDIA

CRIMINAL APPELLATE JURISDICTION

CRIMINAL APPEAL NOS. 1353-1355 OF 2017

PAWAN KUMAR SHARMA  Vs  MANOJ KUMAR & ORS.

Author: PRASANNA B. VARALE, J.

Citation: 2026 INSC 539.

Dated: MAY 25, 2026.

1. The present criminal appeals arise out of the judgment and

order dated 30th January 2015 passed by the High Court of

Judicature for Rajasthan at Jaipur Bench, in D.B. Criminal

Appeal Nos. 923/2008, 844/2008, and 606/2010. By the

impugned judgment and order, the High Court allowed the

appeals of the respondents/accused persons and set aside the

order of conviction and sentence passed by the Trial Court

against respondents/accused persons namely, Manoj Kumar,

Manjeet Kumar @ Billu, Balraj @ Tiloo, and Vijay Singh @ Sunder

under Sections 364 r/w 120B, 302 r/w 120 B, 396 and 201 of

the Indian Penal Code, 1860 [hereinafter referred to as “IPC”].

BRIEF FACTS

2. For the sake of brevity and for maintaining continuity, the

parties are referred to as per their nomenclature before the Trial

Court.

3. The factual matrix of the case is that on 28.04.2007, the

complainant, Pawan Kumar Sharma (P.W.1), submitted a written

2

report before the Police Station Khetri stating that on

26.04.2007, around 5:00 PM, two boys came to his shop and

hired a Bolero Jeep, operated as a taxi by his brother Ashok

Kumar Sharma [hereinafter referred to as “deceased”], to go

towards Lambi Road. The deceased was supposed to return on

the same night, however both the deceased as well as the vehicle

went missing.

4. The report came to be lodged at the instance of P.W. 1

Pawan Kumar Sharma/complainant. On lodgment of report i.e.,

the First Information Report Case no. 122/2007, the criminal

machinery was set into motion and the investigating agency

proceeded. In the course of investigation, four accused persons

namely, Manoj Kumar, Manjeet Kumar @ Billu, Balraj @ Tiloo,

Vijay Singh @ Sunder and Surendra Kumar were arrested. As per

prosecution accused Balraj @ Tiloo was arrested on 28.04.2007

and on the basis of his disclosure statement dead body of

deceased was discovered in a dry well on the same day.

5. The investigation concluded by filing charge sheet against

the accused persons for commission of offences under Sections

364, 302, 396 and 201 read with Section 120B IPC.

3

6. The learned Trial Court framed charges against the four

accused persons whereas one of the accused person namely,

Surender Kumar being juvenile was put to separate trial before

the Juvenile Justice Board.

7. Criminal Sessions Case No. 131/07 was registered against

Balraj @ Tiloo, Manjeet Kumar @ Billu, Vijay Singh @ Sunder, and

Manoj Kumar [hereinafter collectively referred to as

‘respondents/ accused persons’]. In order to prove its case, the

prosecution presented 18 witnesses and submitted 65

documents. The respondents/accused persons, however, did not

examine any witnesses but presented four documents in its

support.

8. The Trial Court on its appreciation of evidence holds all four

respondents/accused persons guilty and vide its judgment and

order dated 26.07.2008 convicted them for committing offences

under Sections 364/120B, 302/120B, 396, and 201 of IPC and

awarded sentences as follows:

IPC Section

found guilty

of

Punishment granted Punishment in

default of fine

364/120B Life Imprisonment + Rs. 500

fine

R.I. for Two

months

302/120B Life Imprisonment + Rs. 500 R.I. for Two

4

fine months

396 Life Imprisonment + Rs. 500

fine

R.I. for Two

months

201 R.I. for 3 years + Rs. 300 fine R.I. for One month

9. Being aggrieved by the judgment and order of the Trial

Court all the respondent/ accused persons challenged the

judgment and order of the Trial Court by way of three separate

appeals, D.B. Criminal Appeal Nos. 923/2008, 844/2008, and

606/2010 before the High Court of Rajasthan at Jaipur.

10. The High Court on its reappreciation and scrutiny of the

evidence found that the evidence led by the prosecution failed to

complete the chain of circumstances so as to hold them guilty for

recording the conviction and awarding the sentence. The High

Court also found that the evidence insofar as the identification is

concerned against one of the accused Vijay Singh @ Sunder is too

weak. Consequently, the High Court set aside the judgment and

order of conviction and sentence passed by the Trial Court.

Resultantly all the four respondents/ accused persons were

acquitted.

11. Aggrieved by the judgment and order passed by the High

Court, complainant/Pawan Kumar Sharma and State of

Rajasthan have preferred separate appeals before us.

5

CONTENTIONS

12. Learned counsel for the appellants, namely, Ms. Sansriti

Pathak, A.A.G. learned counsel for the State of Rajasthan and Mr.

K.L. Janjani, learned counsel for the complainant have

vehemently submitted that the prosecution has established its

case beyond reasonable doubt. Learned counsel further

submitted that evidence in the form of recovery from the

respondent accused along with the other evidence completed the

chain of circumstantial evidence and with the help of this

evidence, the material facts were proved by the prosecution.

Learned counsel further submitted that in such a situation, the

High Court ought not to have granted benefit of doubt to the

accused persons.

13. Learned counsel for the complainant submitted that from

the first instance i.e. in the report lodged by the complainant

itself, it was stated that two boys came in the shop for hiring the

vehicle i.e. bolero and if these two persons are brought before

him, he can identify them. It was further submitted by learned

counsel that P.W.1 Pawan Kumar Sharma (complainant) and

P.W.8 Rajendra Kumar saw the accused persons in the company

of the deceased and it was obligatory on the part of the

6

respondents/ accused persons to explain as to what happened to

the person who was lastly seen in their company and

respondents/ accused persons failed to discharge this burden.

14. Learned counsel further submitted that the High Court

failed to consider the evidence in the form of recovery of the

material objects namely, tape recorder, quartz watch worn by the

deceased recovered at the instance of the accused Manjeet Kumar

@ Billu, towel recovered at the instance of accused Vijay Singh @

Sunder, the papers of bolero jeep of the deceased recovered at the

instance of accused Manoj Kumar and dead body of the deceased,

bolero jeep of the deceased and one lathi recovered at the

instance of accused Balraj @ Tiloo.

15. Learned counsel further submitted that the High Court

erred in appreciating the evidence in the form of postmortem

report which refers to the cause of death firstly due to bone

fractures and secondly strangulation. The postmortem report also

states that all injuries were anti-mortem in nature.

16. Learned counsel further submitted that the High Court

erroneously discarded the evidence in the form of recovery of

dead body from the accused Balraj @ Tiloo on the ground that an

offence under Section 302 IPC was added to the arrest memo

before the body was recovered. It is submitted that there is a

possible explanation for this addition namely, the investigating

officer found the body in dry well and after seeing the body, the

investigating officer naturally added Section 302 IPC in the arrest

memo. Learned counsel further submitted that the delay in the

recovery of dead body could not have been faulted with as the

delay caused due to the bona fide reason namely non-availability

of the chain pulling machine in the village. It is further submitted

that merely because the dead body was not recovered in the

presence of independent witness but in the presence of relative of

deceased could not have been ground to discard the entire

recovery.

17. Learned counsel further submitted that Test Identification

Parade is a tool under Section 9 of the Indian Evidence Act, 1872

[hereinafter referred to as “Evidence Act”] and such test or

tool cannot be applied in the cases of recovery of immovable

articles and admissibility of such evidence would be governed by

Section 27 of Evidence Act.

18. Per contra, learned counsel for the respondents/ accused

persons vehemently supported the judgment of the High Court to

submit that the High Court committed no error in just and

8

proper appreciation of the evidence and resultantly recorded an

order of acquittal.

19. It is submitted by the learned counsel for the respondents/

accused persons that the appeal thus being meritless are liable to

be dismissed.

20. Learned counsel then submitted that the piecemeal recovery

of certain articles which failed to establish the alleged guilt of the

respondents/accused persons. As such, the High Court

committed no error in giving the benefit of doubt to the

respondents/accused persons and resultantly acquitting the

accused persons.

21. The learned counsel in support of his submissions placed

heavy reliance on the judgment of this Court in Tulesh Kumar

Sahu v. State of Chhattisgarh Criminal Appeal No. 753 of

2021 wherein this Court had relied upon the decisions in Sunder

Lal alia Sundera v. State of Madhya Pradesh1 and Sanwant

Khan vs. State of Rajasthan2. The relevant discussion on the

point is in para No. 11.

“11. .....Be that as it may, in the absence of any direct or

circumstantial evidence whatsoever, from the solitary

circumstance of the unexplained recovery of the two articles

1 AIR 1954 SC 28

2 AIR 1956 SC 54

from the houses of the two appellants the only inference that

can be raised in view of illustration A to S.114 of the

Evidence Act is that they are either receivers of stolen

property or were the persons who committed the theft, but it

does not necessarily indicate that the theft and the murders

took place at one and the same time

In our judgment no hard and fast rule can be laid down as

to what inference should be drawn from a certain

circumstance. Where, however, the only evidence against an

accused person is the recovery of stolen property and

although the circumstances may indicate that the theft and

the murder must have been committed at the same time, it is

not safe to draw the inference that the person in possession

of the stolen property was the murdered. Suspicion cannot

take the place of proof.

(Emphasis supplied)

33. In the case of recovery of an article from an accused

person when he stands accused of committing offences other

than theft also, (in this instance murder), what are the tests:

i. The first thing to be established is that the theft and

murder forms part of one transaction. The circumstances

may indicate that the theft and murder must have been

committed at the same time. But it is not safe to draw the

inference that the person in possession of the stolen property

was the murderer [Sanwant Khan (supra)];

ii. The nature of the stolen article;

iii. The manner of its acquisition by the owner; A

iv. The nature of evidence about its identification;

v. The manner in which it was dealt with by the accused;

vi. The place and the circumstances of its recovery;

vii. The length of the intervening period;

viii. Ability or otherwise of the accused to explain its

possession [See Baiju v. State of Madhya Pradesh].”

ANALYSIS

10

22. We have heard learned counsels for the parties at length

and also perused the material placed on record.

23. As referred to above, it is not in dispute that the case of

prosecution entirely rests on circumstantial evidence. It is also

not in dispute that in series of judgments of this Court principles

are laid down by this Court so as to appreciate the substantial

evidence. Admittedly, in the present case, the Trial Court though

passed the judgment and order of conviction and awarded

sentence to the accused, the High Court on reappreciation of the

evidence overturned the judgment and order of the Trial Court

and acquitted the accused of the offences charged against them.

24. Thus, the question before us is whether the High Court was

justified in reversing the order of conviction by granting the

benefit of doubt to the respondents/ accused persons.

25. Before we undertook this exercise, it will not be out of place

to refer to certain judgments of this Court wherein the test for

exercising power under Article 136 of the Constitution of India is

discussed.

26. Firstly, we will refer to the judgment of this Court in State

of M.P. v. Paltan Mallah3. It was held that:

3 (2005) 3 SCC 169

11

“8. … This being an appeal against acquittal, this Court

would be slow in interfering with the findings of the High

Court, unless there is perverse appreciation of the evidence

which resulted in serious miscarriage of justice and if the

High Court has taken a plausible view this Court would not

be justified in interfering with the acquittal passed in favour

of the accused and if two views are possible and the High

Court had chosen one view which is just and reasonable,

then also this Court would be reluctant to interfere with the

judgment of the High Court.”

This view was again reiterated in State of Punjab v. Kewal

Krishan4 wherein it was held as under:

“14. ……Normally, this Court is reluctant to interfere with an

order of acquittal. But when it appears that the High Court

has on an absolutely wrong process of reasoning and a

legally erroneous and perverse approach to the facts of the

case and ignoring some of the most vital facts, acquitted the

respondent and the order of acquittal passed by the High

Court has resulted in a grave and substantial miscarriage of

justice, extraordinary jurisdiction under Article 136 of the

Constitution of India may rightfully be exercised (see : State

of U.P. v. Sahai [State of U.P. v. Sahai, (1982) 1 SCC 352 :

1982 SCC (Cri) 223] ).”

27. On the touchstone of these tests laid by this Court in above

referred judgments, we are of the opinion that the High Court

committed no error in reversing the judgment of conviction and

acquitting all the accused. We may state our reasons supporting

the conclusion arrived at by us as follows.

4 (2023) 13 SCC 695

12

28. The prosecution case, insofar as accused Balraj @ Tiloo,

Manjeet Kumar @ Billu and Manoj Kumar are concerned, rests

entirely on circumstantial evidence. In the case of accused Vijay

Singh @ Sunder, the prosecution case substantially rests upon the

theory of last seen together. The other incriminating

circumstances relied upon by the prosecution include the alleged

recovery of the dead body at the instance of accused Balraj @

Tiloo, the identification of accused Vijay Singh @ Sunder by PW1

Pawan Kumar Sharma and PW8 Rajendra Kumar, and the

recovery of certain articles/objects from the different accused

persons.

29. The High Court has, in our considered opinion, rightly

doubted the prosecution case insofar as the alleged recovery of

the dead body at the instance of accused Balraj @ Tiloo is

concerned. The reasons assigned by the High Court are cogent

and borne out from the record. Firstly, because at the time of

arrest of accused Balraj @ Tiloo police was not aware that the

deceased had been killed as PW1 merely filed a missing report,

then how come on the arrest memo filed on the very same date it

was mentioned that the accused was arrested for offence under

Sections 302, 394 and 201 of IPC. Secondly, the testimony of

P.W.5 Basant Singh, an independent witness, materially

undermines the prosecution case. PW5 in his testimony stated

that police had already visited and examined well from where the

dead body was discovered on 28.04.2007 itself, however since the

boring machine was not available, the dead body was recovered

on 29.04.2007. Further P.W.5 stated that none of the accused

people were present on the spot when the recovery was being

made. High Court observed that the Trial Court has totally

ignored the testimony of PW5, which is a crucial piece of evidence as the said testimony challenges the position of the prosecution. Thirdly, the requirement of independent witnesses, more particularly, as per Section 100(4) of Cr.P.C. is to provide

credibility to the investigation. In the present case, admittedly,

the dead body was recovered in the presence of one witness i.e.

P.W. 2 who happens to be uncle of deceased and another person

namely, Ramawtar who has not been produced by the

prosecution for his examination before the Court.

30. On the backdrop of these facts, the High Court observed

that Ramawtar who was an independent witness and failure to

produce him before the Court is nothing but withholding the

material witness and this creates a doubt about the recovery of

the dead body alleged at the instance of accused Balraj @ Tiloo.

Therefore, the High Court was justified in holding that the

prosecution failed to establish beyond reasonable doubt that the

recovery of dead body was made pursuant to the disclosure

statement of accused Balraj @ Tiloo.

31. It is consistently held by this Court that the suspicion

however strong it may be, cannot take place of the legal evidence

so as to convict an accused person. Considering this position of

law, the High Court was justified in not recording the conviction

against the accused persons on a weak piece of evidence i.e.

recovery of dead body.

32. Furthermore, the discovery of bolero jeep, vehicle belonging

to the deceased at the instance of accused Balraj @ Tiloo has

been rightly doubted by the High Court. As per the testimony of

PW 14, the recovery was made from the road and not from the

accused’s possession. In Jaikam Khan v. State of U.P5 it was

observed: –

5 (2021) 13 SCC 716

15

“One of the alleged recoveries is from the room where

deceased Asgari used to sleep. The other two recoveries are

from open field, just behind the house of deceased Shaukeen

Khan i.e. the place of incident. It could thus be seen that the

recoveries were made from the places, which were accessible

to one and all and as such, no reliance could be placed on

such recoveries.”

Thus, relying on the abovementioned position of law it is clear

that no reliance can be placed on the recovery of the Bolero Jeep.

33. As far as the evidence against Accused Vijay Singh @

Sunder is concerned, PW1 Pawan Kumar and PW8 Rajendra

Kumar have identified him in the Test Identification Parade (Ex

P5, P6, P25, P26) and these both the witnesses have stated before

the Court that they saw the accused Vijay Singh @ Sunder and

Juvenile Surendra had taken deceased with bolero vehicle on hire

basis in the presence of PW1 and PW8. High Court considering

the testimonies of PW1 and PW8 observed as follows:

“Hence, the three pieces of evidence stand out against Vijay:

firstly, the evidence of the last seen; secondly, his silence

about Ashok’s whereabouts; thirdly, his identification by

Pawan Kumar (P.W.1) and by Rajendra Kumar (P. W.2).

Before a person can be convicted; the prosecution must cover

the distance between “may be true” and “must be true.”

However, by establishing the three pieces of evidence,

mentioned above, the prosecution has failed to cover the said

distance. At best, there is a strong suspicion that Vijay may

have been involved in the murder of Ashok. But there is no

16

proof that he must have been Involved In his murder. In

catena of cases, the Hon’ble Supreme Court has held that

last seen is a weak sort of evidence. It is too weak a piece of

evidence to convict a person. Even the identification by

Pawan Kumar (P.W.1) and Rajendra Kumar (P.W.2) does not

unerringly point to the guilt of Vijay. His silence about the

whereabouts of Ashok may be a weakness of the defense,

but the weakness of the defense does not strengthen the

case of the prosecution. Most importantly, it would be utterly

unjust to convict Vijay merely on the basis of a strong

suspicion.”

34. An attempt was made by the Learned Counsel for the

appellant to submit that it was for the respondents/ accused

persons to explain as to what happened to the deceased, as

deceased was last seen in their company and thus burden shifted

upon respondents/ accused persons under section 106 of the

Evidence Act.

35. This Court in Manoj @ Munna v. State of Chhattisgarh,

2025 INSC 1466 has observed as follows:

“30. It is a settled principle that Section 106 of the Indian

Evidence Act, 1872 clearly provides that when a fact lies

especially within the knowledge of a person, the burden of

proving that fact rests upon him. Accordingly, when an

accused is shown to have been last seen in the company of

the deceased, it becomes incumbent upon him to explain

how and when they parted ways. The explanation furnished

must be reasonable, probable, and satisfactory in the opinion

of the Court. If such an explanation is offered, the burden

cast by Section 106 of the Evidence Act stands discharged.

17

However, if the accused fails to present a credible

explanation regarding facts within his special knowledge,

this failure constitutes an additional link in the chain of

circumstantial evidence established against him. At the same

time, it must be emphasized that Section 106 of the Evidence

Act does not shift the primary burden of proof, which in a

criminal trial always remains on the prosecution.

31. Thus, any adverse inference under Section 106 of the

Evidence Act is to be drawn against the accused person

when the prosecution has been able to establish the case

beyond a reasonable doubt.”

36. Further this Court in Manoj @ Munna v. State of

Chhattisgarh, 2025 INSC 1466 while reiterating principle laid

down in Kanhaiya Lal vs. State of Rajasthan6 observed as

follows:

“28. In Kanhaiya Lal vs. State of Rajasthan this Court held

that evidence on last seen together is a weak evidence and

conviction only on the basis of last seen together without

there being any other corroborative evidence against the

accused will not be sufficient to convict the accused for an

offence under Sections 302 and 201 of the IPC.”

37. Considering the aforesaid position of law and the

observations of High Court, it would be appropriate to hold that

the High Court, rightly held that it would be wholly unsafe and

unjust to convict accused Vijay Singh @ Sunder merely on the

basis of a strong suspicion arising from the evidence of last seen

6 (2014) 4 SCC 715

together and identification by PW1 and PW8. We find no infirmity

in the view taken by the High Court in extending the benefit of

doubt to the accused.

38. As far as the recoveries from the accused Manjeet Kumar @

Billu is concerned, though learned counsel for the appellant

heavily relied on the recoveries of the articles, we are unable to

accept the submission of learned counsel to that effect, in view of

the just and proper appreciation of the recoveries by the High

Court in following words:

“Most pertinently, neither the tape recorder, nor the wrist

watch has ever been subjected to the T.I. Parade. Even if

Rajendra Kumar (P. W .8) had identified the tape recorder

and the wrist watch as belonging to Ashok, even then such .

identification is absolutely meaningless In the eyes of law.

For, according to Rajasthan Police Rules, 1965, an object

which is recovered has to be subjected to a test identification

parade in order to assess its objective identification by a

witness. Since neither the tape recorder, nor the wrist watch

was subjected to a test identification parade, it would be too

conjectural to presume that the tape recorder came from the

Jeep and the wrist watch belonged to Ashok. Therefore, the

recovery is insignificant. It does not connect Manjeet to the

alleged crime. If he were to be convicted on the basis of this

flimsy recovery, he would be convicted on the basis of

conjectures and surmises. But under criminal jurisprudence,

a moral conviction is impermissible. The conviction has to be

a legal one.”


The view taken by the High Court also finds support from

the decision of this Court in Thammaraya & Anr. v. The State

Of Karnataka (2025) 3 SCC 590 wherein this Court has reiterated the law relating to Test Identification Parade of recovered articles. It observed as follows:

“27. Therefore, this material omission on part of the

Investigating Officer (PW-27) in not conducting a Test

Identification Parade (TIP) of the recovered articles, more

particularly when the case of prosecution is based solely

upon recoveries of these articles, has created holes in the

fabric of the prosecution story, which are impossible to

mend.

28. Every piece of relevant fact needs to be sewn via the

golden thread of duly proved circumstances, in order to

ultimately formulate the fabric of guilt. Sadly, in the present

case, the facta probantia fails to sustain and support the

alleged factum probando, rendering the prosecution’s case

miserably weak. Hence, the evidence led by the prosecution

against the accused person is woefully short of the mandate

to prove the case beyond reasonable doubt.”

39. Further, although the prosecution recovered a towel from

the house of accused Vijay Singh alleging the same to be the

murder weapon, such recovery is wholly immaterial inasmuch as

a towel is a common household object ordinarily found in every

residence and, therefore, in absence of any connecting material,

no inference can be drawn against the respondent/accused. It is

further the case of the prosecution that the lathi recovered at the

instance of Balraj @ Tiloo was used in the assault upon the

deceased, however, the said towel neither bore any bloodstains

nor any other incriminating material connecting towel to the

deceased. Consequently, the mere recovery of a towel without any

incriminating material does not connect the respondent/accused

with the alleged crime.

40. A holistic appreciation of the evidence confirms the High

Court’s observation that the prosecution’s evidence is disjointed

and not interlinked. Instead of placing the Court on a firm

footing, the prosecution has left it “groping in the dark”. We find

that the High Court meticulously “separated grain from the chaff”

and arrived at a plausible conclusion that the chain of

circumstances was incomplete.

41. The law regarding circumstantial evidence has been

crystallised by this Court in an oftenly quoted judgment of this

Court in Sharad Birdhichand Sarda v. State of

Maharashtra (1984) 4 SCC 116, as follows-


“152. Before discussing the cases relied upon by the

High Court we would like to cite a few decisions on

the nature, character and essential proof required in a

criminal case which rests on circumstantial evidence

alone. The most fundamental and basic decision of

this Court is Hanumant v. State of Madhya Pradesh

[(1952) 2 SCC 71 : AIR 1952 SC 343 : 1952 SCR 1091

: 1953 Cri LJ 129] . This case has been uniformly

followed and applied by this Court in a large number

of later decisions up-to-date, for instance, the cases of

Tufail (Alias) Simmi v. State of Uttar Pradesh [(1969) 3

SCC 198 : 1970 SCC (Cri) 55] and Ramgopal v. State

of Maharashtra [(1972) 4 SCC 625 : AIR 1972 SC

656] . It may be useful to extract what Mahajan, J.

has laid down in Hanumant case [(1952) 2 SCC 71 :

AIR 1952 SC 343 : 1952 SCR 1091 : 1953 Cri LJ 129]

:

“It is well to remember that in cases where the

evidence is of a circumstantial nature, the

circumstances from which the conclusion of guilt is to

be drawn should in the first instance be fully

established, and all the facts so established should be

consistent only with the hypothesis of the guilt of the

accused. Again, the circumstances should be of a

conclusive nature and tendency and they should be

such as to exclude every hypothesis but the one

proposed to be proved. In other words, there must be a

chain of evidence so far complete as not to leave any

reasonable ground for a conclusion consistent with the

innocence of the accused and it must be such as to

show that within all human probability the act must

have been done by the accused.”

42. Thus, it is a settled position of law that to convict the

accused on the basis of circumstantial evidence, the prosecution

must prove beyond reasonable doubt each of the incriminating

circumstances on which it proposes to rely; the circumstance(s)

relied upon must be of a definite tendency unerringly pointing

towards the accused’s guilt and must form a chain so far

complete that there is no escape from the conclusion that within

all human probability it is the accused and no one else who had

committed the crime and they (it) must exclude all other

hypothesis inconsistent with his guilt and consistent with his

innocence.

43. For all the reasons above, while keeping in mind that the

view taken by the High Court is a plausible view, we do not find a

good reason to interfere with the order of acquittal passed by the

High Court. The appeals are accordingly dismissed.

........................................J.

[PANKAJ MITHAL]

.........................................J.

[PRASANNA B. VARALE]

NEW DELHI;

MAY 25, 2026.


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