Supreme Court Holds That Acquittal Cannot Be Reversed in a Circumstantial Evidence Case Where the Chain of Circumstances Is Incomplete and Confessional Statements Are Unreliable and Uncorroborated

Held: The Supreme Court held that the High Court was not justified in reversing the acquittal recorded by the Trial Court, as the prosecution failed to establish a complete chain of circumstances, the last-seen theory was not proved, recoveries and discoveries were unreliable, and the confessional statements were neither voluntary nor inculpatory nor corroborated by independent evidence so as to sustain a conviction in a case based purely on circumstantial evidence.

Summary: The case arose from a missing person complaint that led to recovery of a dead body from a graveyard and prosecution of the appellants for murder and causing disappearance of evidence. The Trial Court acquitted the accused after finding that the circumstantial evidence, including last-seen theory, recoveries, medical opinion, ransom calls and confessional statements under Section 164 CrPC, did not form a coherent chain pointing to guilt. The High Court reversed the acquittal and convicted the accused. On appeal, the Supreme Court closely scrutinised the medical and forensic evidence, inconsistencies in recoveries, absence of a proximate last-seen link, procedural lapses in identification and seizure, and serious infirmities in the recording of confessions, including absence of legal assistance and exculpatory content. Applying settled principles governing circumstantial evidence and appellate interference with acquittals, the Court held that the Trial Court’s view was a plausible and reasonable view that could not have been displaced.

Decision: The appeals were allowed, the judgment of the High Court convicting the accused was set aside, the acquittal recorded by the Trial Court was restored, and it was directed that the accused be released forthwith if in custody and that their bail bonds, if any, stand cancelled, with all pending applications disposed of.