Can convictions based solely on circumstantial evidence be sustained when the chain of events contains significant gaps?

Summary

Category	Data
Court	Supreme Court of India
Case Number	Crl.A. No.-002069-002069 – 2024
Diary Number	14982/2023
Judge Name	HON’BLE MR. JUSTICE DIPANKAR DATTA
Bench	HON’BLE MR. JUSTICE DIPANKAR DATTA HON’BLE MR. JUSTICE AUGUSTINE GEORGE MASIH
Precedent Value	Binding
Overrules / Affirms	Affirms existing precedents on circumstantial evidence; quashes lower-court convictions
Type of Law	Criminal law; Evidence law
Questions of Law	Parameters for sustaining convictions on circumstantial evidence Application of “panchsheel” principles Proof beyond reasonable doubt
Ratio Decidendi	The prosecution must establish a complete, unbroken chain of incriminating circumstances; any missing link or unexplained gap gives rise to reasonable doubt, entitling the accused to acquittal.
Judgments Relied Upon	Karakkattu Muhammed Basheer v. State of Kerala (2024) 10 SCC 813 Ramreddy Rajesh Khanna Reddy v. State of A.P. (2006) 10 SCC 172 State of U.P. v. Satish (2005) 3 SCC 114 Kali Ram v. State of Himachal Pradesh (1973) 2 SCC 808
Logic / Jurisprudence / Authorities Relied Upon by the Court	“Panchsheel” principles on circumstantial proof (Ramreddy; Basheer); “last seen” theory; benefit-of-doubt doctrine
Facts as Summarised by the Court	An 85-year-old woman was strangled and raped; two gold bangles were missing. No eyewitnesses; investigation relied on circumstantial links, witness statements, Mahazar report and alleged hospital confession and recovery.

Category	Impact
Binding On	All subordinate courts
Persuasive For	High Courts
Overrules	Lower-court judgments convicting the appellant
Follows	Karakkattu Muhammed Basheer v. State of Kerala Ramreddy Rajesh Khanna Reddy v. State of A.P. State of U.P. v. Satish Kali Ram v. State of Himachal Pradesh

Reaffirmation that even strong circumstantial evidence must form a complete, unbroken chain; any missing link mandates doubt.
Non-association or non-examination of a key witness can vitiate the entire circumstantial narrative.
Doubts on the legality of arrest and identity of informant can undermine alleged recovery of incriminating articles.
Absence of forensic corroboration (fingerprints, bodily samples) in a murder-plus-rape case precludes conviction.
Highlights the necessity of test identification parades and recording informant details in investigations.

Cited “panchsheel” principles (Ramreddy; Karakkattu Basheer) requiring a chain of circumstances permitting no hypothesis but guilt.
Applied the “last seen” theory: death window (9 p.m.–2 a.m.) vis-à-vis appellant’s movements (smoking break at 2 a.m.; seen leaving compound at 2:45 a.m.).
Identified missing link: failure to record the statement of Marcus, who last accompanied appellant, undermines opportunity analysis.
Questioned the credibility of the arrest and confession at hospital—no informant identity, no test parade, possible torture narrative.
Noted absence of forensic evidence at scene or on person; sniffer dog and fingerprint expert yielded no link.
Concluded that significant gaps in the circumstantial chain create reasonable doubt, requiring acquittal.

Concurrent findings of guilt by trial and High Court based on properly appreciated circumstantial evidence.
Recovery of two gold bangles from appellant after his voluntary confession at hospital.
Witness (PW-5) saw appellant near the compound around the time of death.

An 85-year-old woman living alone was found strangled with a towel, sexually assaulted, and two gold bangles missing.
FIR under Sections 302, 449, 376, 394 IPC; investigator prepared Mahazar, collected blood-stained material, involved sniffer dog, fingerprint expert.
Neighbours observed appellant leaving a nearby compound around 2–3 a.m.; two days later, he was allegedly arrested on an over-bridge and taken to hospital.
At the hospital, he purportedly confessed and produced the bangles from his pocket; trial court convicted and High Court upheld the verdict.

IPC Section 302: Punishment for murder.
IPC Section 449: House-trespass in order to commit offence.
IPC Section 376: Rape.
IPC Section 394: Voluntarily causing hurt in committing robbery or dacoity.
CrPC Section 313: Examination of accused’s statement; here appellant denied arrest narrative and recovery.