Arun Shankar vs. The State of Madhya Pradesh
Background
The appellant had been convicted by a Sessions Court in 1995 for the murder of a relative and fellow villager, Sushildhar Dubey, and sentenced to life imprisonment; the conviction was upheld by the Madhya Pradesh High Court in 2017. The prosecution's case rested entirely on circumstantial evidence: the two men had been drinking liquor together on the night in question, the deceased was last seen with the appellant, a knife (the alleged murder weapon) was said to have been recovered based on the appellant's disclosure, and medical evidence on the cause of death.
Decision Breakdown
The Supreme Court found that the prosecution had failed to prove the recovery of the knife at the appellant's instance, breaking a key link in the chain of circumstances. It further noted that a witness had testified to finding broken glass pieces at the scene, and the post-mortem doctor conceded the injury could have been caused by such glass, raising real doubt about the prosecution's version and pointing toward the possibility of an accident (such as a motorcycle collision) rather than a deliberate assault. The Court held that "last seen together" alone is a weak circumstance, and since the circumstances proved were not conclusive or exclusively consistent with guilt, the conviction could not be sustained. The appeal was allowed, the conviction was set aside, and the appellant was acquitted and his bail bonds cancelled.
Lesson Learnt
A criminal conviction based purely on circumstantial evidence requires every link in the chain to be proved beyond reasonable doubt and to be consistent only with guilt. If even one link (such as recovery of the weapon) fails, or a plausible innocent explanation exists, the conviction cannot stand.