Circumstantial Evidence Must Form a Complete Chain Before a Death Sentence Can Stand: Supreme Court Acquits Accused in Rape-Murder Case

Case Name: Mehtab v. State of Uttarakhand with Criminal Appeal No(s). 1340-1341 of 2018

Citation: 2026 INSC 578

Date of Judgment/Order: May 27, 2026

Bench: Justice Vikram Nath, Justice Sandeep Mehta and Justice Vijay Bishnoi

Held: The Supreme Court held that where a criminal case rests entirely on circumstantial evidence, every incriminating circumstance must be firmly proved and the full chain must point only towards the guilt of the accused, leaving no reasonable possibility of innocence. The Court held that weak “last seen” evidence, doubtful identification based on unproved sketches, failure to conduct a Test Identification Parade where the accused were strangers to the witnesses, suspicious recoveries, broken chain of custody, and inconclusive forensic evidence cannot sustain a conviction, much less a death sentence. The Court further held that suspicion, however strong, cannot replace legal proof, and when the prosecution’s evidence suffers from serious infirmities, the accused must receive the benefit of doubt.

Summary: The case concerned the alleged rape and murder of a 55-year-old woman, Munni Devi, who had gone to the forest for grazing goats and was later found dead in a partially unclothed condition. The prosecution case was based entirely on circumstantial evidence, mainly that two unknown youths had asked witnesses about the whereabouts of the deceased, sketches were prepared on the basis of their description, and the appellants were later arrested with alleged recoveries of a shirt, a torn pocket, salwar and ornaments. The Trial Court convicted the appellants under Section 302 read with Section 34 IPC and Section 376(2)(g) IPC and sentenced them to death for murder, while the High Court affirmed the conviction and death sentence, though it acquitted them under Section 3(2)(v) of the SC/ST Act. The Supreme Court found that the prosecution failed to prove the last-seen circumstance because the witnesses had not actually seen the appellants with the deceased, the accused were not previously known to the witnesses, no TIP was conducted, the sketch artist was not examined, the original sketches were not produced, and a material witness was withheld. The Court also found the alleged recoveries and forensic evidence unsafe due to delay, doubtful seizure, lack of chain of custody, absence of DNA linkage, and serious procedural irregularities.

Decision: The Supreme Court allowed the appeals, set aside the judgment of conviction dated January 23, 2014 and order of sentence dated January 27, 2014 passed by the Trial Court, as well as the common judgment dated April 27, 2018 passed by the High Court of Uttarakhand. The appellants were acquitted of all charges, their conviction and sentences including the death sentence were set aside, and they were directed to be released from custody forthwith, if not required in any other case. Pending applications, if any, were also disposed of.