Suspicion Cannot Replace Proof: Supreme Court Acquits in Loan-Dispute Murder Case
Case Name: Nagamma @ Nagarathna & Ors. v. The State of Karnataka
Citation: 2025 INSC 1135
Date of Judgment: 22 September 2025
Bench: Justice K. Vinod Chandran and Justice K. V. Viswanathan (DB)
Held: The Supreme Court held that the prosecution failed to establish a complete and cogent chain of circumstances pointing towards the guilt of the accused. The alleged motive of a loan dispute was unsubstantiated, extra-judicial confessions made inside a police station were inadmissible under Sections 25 and 26 of the Evidence Act, and the recovery of a weapon was not credibly proved. The Court reiterated that conviction cannot rest on suspicion or unreliable testimony; guilt must be proven beyond reasonable doubt.
Summary: The prosecution alleged that the deceased, a police driver, was murdered at the instigation of another policeman (A1) by his wife (A2) along with her brother (A3) and brother-in-law (A4). The trial court convicted A2 to A4 under Section 302 read with Section 34 IPC and sentenced them to life imprisonment, while A1 was acquitted on the ground of alibi. The High Court affirmed the convictions. On appeal, the Supreme Court examined the circumstantial evidence and found it wholly insufficient. The supposed motive of a loan transaction of ₹1 lakh was not proved, as the witnesses relied upon were either hostile or unreliable, and even the wife of the deceased denied any knowledge of such a transaction. The evidence regarding the presence of the dead body at the house of A2 was conflicting, with several witnesses, including the wife of the deceased, stating that they had first seen the body only at the hospital. The extra-judicial confessions attributed to A2 were all made within the police station, either before police officials or in their presence, and were therefore inadmissible under Sections 25 and 26 of the Evidence Act. The recovery of a chopper said to be at the instance of A4 was also not reliable, since the disclosure lacked clarity and the panch witnesses turned hostile. In the absence of cogent, credible and consistent evidence, the Court held that suspicion alone could not form the basis of conviction.
Decision: The Supreme Court allowed the appeal, set aside the convictions of A2 to A4 under Section 302/34 IPC, and acquitted all accused. Those in custody were ordered to be released forthwith unless required in any other case; if on bail, their bail bonds stood cancelled.