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Anjan Kumar Sarma & Ors. v. State of Assam

Criminal Appeal · 2017 INSC 467Decided 23 May 2017
Criminal Appeal No. 560 of 2014
Justice L. Nageswara Rao · Justice Navin Sinha

Background

A young woman was found dead, dismembered on a railway track near a tea estate in Assam in December 1992, after last being seen in the company of the appellants (tea estate staff) and a co-accused the previous evening. The accused were acquitted by the trial court, but the High Court reversed that acquittal and convicted the appellants of murder and destruction of evidence, relying mainly on the "last seen together" circumstance and the absence of any explanation from the accused.

Decision Breakdown

The Supreme Court held that circumstantial evidence must form a complete, unbroken chain pointing only to guilt, and found that key links relied on by the prosecution, recovery of the murder weapon (a khukri) and bloodstain evidence, were not reliably proved, since the recovery witnesses turned hostile and forensic reports on the blood were negative or inconclusive. With those circumstances unproved, only "last seen together" and the accused's silence remained, which, per settled precedent, cannot by themselves sustain a conviction. The Court also found the High Court's inference about the time of death was not supported by the medical evidence on record. It therefore set aside the High Court's conviction and restored the trial court's acquittal.

Lesson Learnt

In a case built only on circumstantial evidence, courts must be satisfied that every link in the chain is proven beyond doubt, being "last seen" with the victim and offering no explanation is not, by itself, enough to convict someone of murder.

Official source (sci.gov.in)View Judgment (PDF)

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