Supreme Court Acquits Accused in Murder Case; Holds Circumstantial Evidence Incomplete and Voice Identification Unreliable

Held: The Supreme Court held that conviction based solely on circumstantial evidence cannot be sustained unless every link in the chain is conclusively established, and where identification is doubtful and evidence leaves room for multiple interpretations, the accused is entitled to benefit of doubt.

Summary: The case arose from the conviction of a constable for the alleged murder of his superior officer using a service rifle, purportedly due to denial of leave. The prosecution case was entirely based on circumstantial evidence, including testimony of a post-occurrence witness (PW-3), alleged confession, ballistic evidence, and duty registers. The Supreme Court found that PW-3’s testimony was unreliable as he admitted during cross-examination that due to darkness he could not clearly see the accused and identified him only by voice, thereby materially weakening the prosecution’s case. The Court also noted that other witnesses were either hearsay or hostile, and the evidence regarding the weapon of offence was inconclusive, particularly due to unexplained discrepancies in rifle allocation and absence of crucial duty register entries for the date of incident. Reiterating settled law from Sharad Birdhichand Sarda, the Court emphasized that circumstantial evidence must form a complete chain pointing only to the guilt of the accused and excluding every other hypothesis. In the present case, the chain was found to be incomplete and based on suspicion rather than proof beyond reasonable doubt.

Decision: The Supreme Court allowed the appeal, set aside the conviction and sentence under Section 302 IPC and Section 27 of the Arms Act, acquitted the appellant, directed his release forthwith if not required in any other case, and granted liberty to seek reinstatement or compensation from the appointing authority, with pending applications disposed of accordingly.