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Chandru @ Chandrasekaran v. State rep. by Deputy Superintendent of Police, CB CID and Anr.

Criminal Appeal · 2019 INSC 176Decided 12 Feb 2019
Criminal Appeal No. 1193 of 2011
Justice Sanjay Kishan Kaul · Justice Deepak Gupta

Background

A young man, Arun, died of a drug overdose after a night out with two friends (the appellants) and one Venki, who administered the injection. Years later, after the original accused (Venki) died before trial, the deceased's family filed a private complaint alleging that the two friends had conspired with Venki to murder Arun out of jealousy over a woman. Both the trial court and the High Court convicted the two friends of murder based on circumstantial evidence, despite there being no eyewitnesses.

Decision Breakdown

The Supreme Court undertook a detailed re-examination of each circumstance relied upon by the prosecution and found the chain of circumstantial evidence fatally incomplete: the medical evidence could not establish when or how a second, fatal dose of the drug was administered, no drugs or syringes were recovered from the accused, the alleged jealousy motive was unsupported and introduced only four years after the incident, and the theory that the accused (a medical student) injected the fatal dose was pure conjecture with no evidentiary basis. Applying the settled rule that circumstantial evidence must exclude every hypothesis other than guilt, the Court held the prosecution had failed to prove its case beyond reasonable doubt and had not even conclusively shown the death was homicidal. Both appeals were allowed and the accused were acquitted and ordered released.

Lesson Learnt

A criminal conviction cannot rest on suspicion, delayed allegations, or an incomplete chain of circumstances: in cases without direct eyewitnesses, every link in the chain of circumstantial evidence must be proven beyond doubt and must point unerringly, and only, to the guilt of the accused.

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

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