Chandrabhan Sudam Sanap v. The State of Maharashtra

Criminal Appeal · 2025 INSC 116Decided 28 Jan 2025
Criminal Appeal No. 879 of 2019
Justice B.R. Gavai · Justice Prashant Kumar Mishra · Justice K.V. Viswanathan

Background

A 23-year-old woman went missing in January 2014 while travelling by train to Mumbai; her burnt, decomposed body was later found and identified through a ring on her finger. The trial court convicted the appellant of kidnapping, rape and murder and sentenced him to death, and the Bombay High Court confirmed the conviction and sentence, since there was no direct eyewitness and the case rested entirely on circumstantial evidence: recoveries of belongings and an alleged extra-judicial confession.

Decision Breakdown

The Supreme Court closely scrutinised each strand of evidence and found it riddled with holes: the extra-judicial confession witness had troubling links to the police and unexplained omissions in his statement; the recovery of a motorcycle and a trolley bag was poorly documented, lacked independent local witnesses, and one key witness admitted she had been pressured and threatened by police into deposing and giving a thumb impression she couldn't read. Applying the settled rule that circumstantial evidence must form a complete, unbroken chain pointing only to guilt (and to no other reasonable explanation), the Court held the prosecution's case fell well short of that standard. It allowed the appeal, set aside the conviction and death sentence, and ordered the appellant's release.

Lesson Learnt

A death sentence, or any conviction, cannot rest on suspicion, shaky recoveries, or a confession extracted under doubtful circumstances. Where there is no direct evidence, every link connecting the accused to the crime must be independently and reliably proved, and courts must acquit if any reasonable possibility other than guilt remains open.

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