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Guna Mahto vs. State of Jharkhand

Criminal Appeal · 2023 INSC 240Decided 16 Mar 2023
Criminal Appeal No. 108 of 2023
B.R. Gavai · Sanjay Karol · Vikram Nath

Background

Guna Mahto was convicted by the trial court in 1989 for murdering his wife and dumping her body in a village well, and was sentenced to life imprisonment; the Jharkhand High Court upheld the conviction in 2004. The prosecution's case rested entirely on circumstantial evidence and the testimony of relatives, since no independent witness saw the killing and the Investigating Officer himself was never examined at trial.

Decision Breakdown

The Supreme Court found that the witnesses relied on by the lower courts gave only hearsay or vague suspicion: e.g., one witness said villagers "suspected" the accused because he "used to beat her," without any specifics of time or place, and this claim surfaced for the first time only in court. The Court held that circumstantial evidence must form a complete, unbroken chain pointing solely to guilt, and here it did not: no evidence connected the accused to the actual killing, and the police officer who investigated was never put on the witness stand to prove key facts. Applying the settled principle that mere suspicion, however strong, cannot substitute for proof beyond reasonable doubt, the Court set aside both lower court judgments and acquitted the appellant, discharging his bail bond.

Lesson Learnt

A criminal conviction cannot rest on suspicion, rumour, or the fact that an accused was "last seen" with the victim. The prosecution must build an unbroken chain of proven facts pointing exclusively to guilt, and gaps such as never examining the investigating officer can be fatal to the case even years after conviction.

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

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