Inam Singh@Bhura vs. The State (NCT of Delhi)
Background
In 2000, a man died of head injuries after an evening of drinking with the appellant and two others at a rented room in Najafgarh. The two companions said that when they returned after a few hours, they found the door bolted from inside, and the appellant told them he had hit the deceased with an iron pipe after a quarrel. The trial court convicted the appellant of murder in 2002, relying mainly on the "last seen together" theory and an alleged confession made to those companions, sentencing him to life imprisonment. The appeal against that conviction remained pending in the High Court for over two decades before being decided, with the appellant finally represented through a court-appointed amicus curiae.
Decision Breakdown
The High Court found that the two prosecution witnesses who claimed to have last seen the appellant with the deceased gave inconsistent, unnatural, and uncorroborated accounts of their own movements that night, undermining their reliability. There was no forensic evidence linking the recovered iron pipe to the injuries, no motive was established, and the alleged extra-judicial confession could not be relied upon given the doubts surrounding these witnesses. Applying the Supreme Court's settled "panchsheel" (five golden principles) test for circumstantial evidence cases, the Court held that the chain of circumstances was incomplete and did not exclude every possibility other than the appellant's guilt.
Lesson Learnt
A conviction cannot rest on the "last seen together" circumstance alone, however suspicious it looks. The prosecution must build a complete, gap-free chain of evidence that leaves no reasonable possibility of innocence, and any genuine doubt must benefit the accused, not the prosecution.