In Case Of Circumstantial Evidence, Chain Has To Be Complete In All Respect : Supreme Court

Reiterating that in a case of circumstantial evidence, "the chain has to be complete in all respects so as to indicate the guilt of the accused and also exclude any other theory of the crime," the Supreme Court has set aside the conviction and life sentence awarded to the accused in the murder case by the Madhya Pradesh High Court in 2010.

The Court was hearing the appeal against the conviction based on circumstantial evidence.

The bench of Justice Vikram Nath and Justice Ahsanuddin Amanullah noted that the High Court agreed with the finding of motive and the last seen, but it held that the recovery of the weapon of assault and blood-stained clothes was “invalid.”

“…also (High Court) goes to the extent to say that the recovery which has been made does not indicate that the appellant has committed the offence. Still, it observed that looking to the entire gamut and other clinching evidence against the appellant of last seen and motive, affirmed the conviction,” the Court observed.

We do not find such a conclusion of the High Court to be strictly in accordance with law, it opined.

Referring to Sharad Birdhichand Sarda vs. State of Maharashtra and Sailendra Rajdev Pasvan vs. State of Gujarat Etc., the Court reiterated that in a case of circumstantial evidence, “the chain has to be complete in all respects so as to indicate the guilt of the accused.”

Thus,if the High Court found one of the links to be missing and not proved in view of the settled law on the point, the conviction ought to have been interfered with, said the Court.

Consequently, the appeal was allowed and conviction and sentence to life imprisonment was set aside.

Case Title- Laxman Prasad @Laxman v.State of Madhya Pradesh

Citation : 2023 LiveLaw (SC) 489

Click here to read the judgment