The Chhattisgarh High Court clarified that where the chain of circumstantial evidence is incomplete, uncorroborated extra-judicial confessions are present, and last-seen and forensic links are lacking, conviction cannot be sustained. The judgment upholds the established requirement that every circumstance must be proved beyond reasonable doubt and that suspicion, however strong, cannot substitute proof. This decision reaffirms the binding standards for circumstantial evidence and will serve as binding authority within the State, with persuasive value elsewhere.
Summary
| Category | Data |
|---|---|
| Case Name | CRA/584/2019 of BASANT YADAV Vs STATE OF CHHATTISGARH |
| CNR | CGHC010119752019 |
| Date of Registration | 03-04-2019 |
| Decision Date | 11-09-2025 |
| Disposal Nature | ALLOWED |
| Judgment Author | HON’BLE SMT. JUSTICE RAJANI DUBEY |
| Concurring or Dissenting Judges | HON’BLE SHRI JUSTICE AMITENDRA KISHORE PRASAD |
| Court | High Court Of Chhattisgarh |
| Bench | Division Bench (Rajani Dubey, Amitendra Kishore Prasad) |
| Precedent Value | Binding within Chhattisgarh; Persuasive elsewhere |
| Overrules / Affirms | Affirms established Supreme Court standards on circumstantial evidence |
| Type of Law | Criminal Law (Standard of Proof; Circumstantial Evidence; Indian Penal Code section 302/34) |
| Questions of Law | Whether conviction for murder can be sustained on the basis of incomplete circumstantial evidence and uncorroborated confessions |
| Ratio Decidendi |
The Court held that to sustain a conviction based on circumstantial evidence, each circumstance must be established beyond reasonable doubt, forming a complete chain leading only to the guilt of the accused; extra-judicial confessions without corroboration are weak evidence, and suspicion, however strong, cannot replace proof. The prosecution having failed to establish the chain of evidence, last-seen or forensic links, and independent corroboration, the benefit of doubt must be given to the accused and conviction cannot stand. |
| Judgments Relied Upon |
|
| Logic / Jurisprudence / Authorities Relied Upon by the Court |
The Court applies the “last seen together” principle, considers criteria for admissibility of extra-judicial confession, and emphasizes the requirement for every link in a chain of circumstantial evidence to be firmly established; follows Supreme Court jurisprudence regarding benefit of doubt and the presumption of innocence. |
| Facts as Summarised by the Court |
Prosecution alleged the appellants murdered Indramani Yadav (wife of one appellant) by strangulation; conviction was based on circumstantial evidence including last-seen evidence, extra-judicial confession, and recovery of scarf. Defence argued absence of motive, weak/inconsistent witness testimony, and no forensic corroboration. Court found fatal gaps in evidence and acquitted the appellants. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts in Chhattisgarh |
| Persuasive For | High Courts & Supreme Court (as additional corroboration of established precedent) |
| Follows |
|
| Distinguishes | Trial Court’s reliance on uncorroborated and incomplete circumstantial evidence; clarifies proper standard for circumstantial case convictions |
What’s New / What Lawyers Should Note
- Reaffirms the legal principle that conviction cannot be based solely on weak, uncorroborated circumstantial evidence or extra-judicial confessions.
- Clarifies that the chain of circumstances must be complete and exclude every hypothesis except the guilt of the accused.
- Highlights the inadmissibility of extra-judicial confessions made in the presence of police or under suspicious circumstances.
- Emphasizes failure to conduct or prove forensic/chemical examination as a fatal flaw when the weapon or material object is crucial to prosecution.
- Demonstrates that delay in recording recovery or memorandum statements undermines evidentiary value.
- Reminds that benefit of doubt must be extended where the prosecution’s case is based on suspicion rather than proof.
Summary of Legal Reasoning
- The Court scrutinized the chain of circumstances, noting that prosecution relied on last-seen evidence, alleged extra-judicial confession, and recovery of a scarf (claimed murder weapon).
- After detailed witness analysis, the Court observed conflicting testimony, lack of direct evidence linking the accused to the crime at the material time, and several admitted gaps, such as a broken wall at the scene and non-examination of key forensic evidence.
- The Court applied the principle (from Sharad Birdhichand Sarda, Sujit Biswas, and Banabihari Mohapatra) requiring each incriminating circumstance to be firmly established and form a complete chain, to the exclusion of any other hypothesis.
- The alleged extra-judicial confessions were found inadmissible because they occurred in the presence of police and/or under duress, in contravention to Sections 24 and 25 of the Indian Evidence Act and as clarified by the Supreme Court in Ratnu Yadav.
- The “last seen together” evidence was discounted due to poor quality, timeline inconsistencies, and lack of corroborative evidence; no independent forensic proof linked the recovered scarf to the murder.
- Stressing the rulings in Raja Naykar regarding delayed recovery of evidence and Banabihari Mohapatra on high standard of proof in circumstantial cases, Court held that mere strong suspicion is insufficient.
- As prosecution failed to prove circumstances beyond reasonable doubt, and defence supplied a plausible case for false implication (property dispute), the Court granted acquittal giving benefit of doubt.
Arguments by the Parties
Petitioner (Appellants):
- Challenged findings based on incomplete chain of circumstances and weak circumstantial evidence.
- Argued there was no material or credible evidence directly linking the appellants to the crime.
- Contended the case was based mostly on uncorroborated extra-judicial statements and presumption.
- Pointed out lack of motive and inconsistencies among prosecution witnesses.
- Highlighted questionable recovery, delayed memorandum statement, and failure to conduct key forensic examination.
Respondent (State):
- Supported conviction, stating trial court had rightly appreciated all evidence (oral & documentary).
- Relied on previous judicial decisions and asserted belief in the trustworthiness of the prosecution’s case and findings.
- Emphasized statements and confessions as linking the accused to the crime.
Factual Background
The case concerned the murder of Indramani Yadav, who was found dead in her shop. Accusation centered on her husband Basant Yadav and another appellant, with prosecution relying on circumstantial evidence, such as last-seen, extra-judicial confession, and recovery of scarf. The trial court convicted the appellants, but the High Court found key evidentiary gaps, conflicting witness testimony, lack of forensic corroboration, and no direct proof connecting the accused to the incident, ultimately leading to acquittal.
Statutory Analysis
- Indian Penal Code s. 302/34: Interpreted as requiring the prosecution to establish all ingredients (act of murder, common intention) beyond reasonable doubt, especially in a circumstantial evidence case.
- Indian Evidence Act, Sections 24 & 25: Extra-judicial confessions made in the presence of police or under duress found inadmissible.
- CrPC s. 313: Accused’s right of defence and explanation evaluated.
- Supreme Court precedents (Sharad Birdhichand Sarda, Sujit Biswas, Raja Naykar): Court adopted settled tests for circumstantial cases—each circumstance must be proved, chain complete, exclusion of other hypothesis, and strict scrutiny of evidence.
Dissenting / Concurring Opinion Summary
There was no dissent. Both judges (Rajani Dubey and Amitendra Kishore Prasad) agreed and delivered a unanimous decision.
Procedural Innovations
- The Court reiterated the procedural necessity of timely and professionally conducted evidence recovery and forensic examination.
- Directed that upon acquittal, personal bonds be executed under provisions of the BNS S. 481 to secure future appearance in the event of any SLP before the Supreme Court.
Alert Indicators
- ✔ Precedent Followed – The decision faithfully reaffirms and applies established Supreme Court precedent on the evidentiary requirements for conviction in circumstantial evidence cases, particularly the need for every circumstance to be proved beyond reasonable doubt and for the chain to be complete.