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Maghavendra Pratap Singh @ Pankaj Singh vs. The State of Chhattisgarh (Criminal Appeal No. 915 of 2016)

Criminal Appeal · 2023 INSC 415Decided 24 Apr 2023
Criminal Appeal No. 915 of 2016
B.R. Gavai · Sanjay Karol

Background

A businessman was shot dead by two motorcyclists in Chhattisgarh in 2009 after being threatened for money. Seven people, including the appellant Pankaj Singh, were tried for the murder and related conspiracy; the trial court convicted several of them, but on appeal the High Court acquitted everyone except Pankaj Singh, upholding his life sentence for murder, destruction of evidence, and illegal possession of arms based entirely on circumstantial evidence (no eyewitness saw him commit the crime).

Decision Breakdown

The Supreme Court closely scrutinized the investigation and found it riddled with serious flaws: the investigating officer failed to properly document key witnesses, movements, and recoveries; the arrest and recovery memos were not verified by him and were altered; and no scientific/forensic report was ever proved in court to link the recovered weapon to the accused. The Court reiterated that in cases built purely on circumstantial evidence, the law demands certainty, not mere probability: every piece of evidence must point exclusively to the guilt of the accused with no other reasonable explanation. Finding that the High Court had wrongly convicted the appellant based on "probability" rather than the required standard of conclusive proof, and given the same unreliable investigation had led to the acquittal of all other co-accused, the Supreme Court set aside the conviction, allowed the appeal, and ordered the appellant's release.

Lesson Learnt

A criminal conviction based only on circumstantial evidence cannot stand unless the evidence conclusively and exclusively points to the accused's guilt, ruling out every other possibility, and a poorly documented, careless police investigation can be fatal to even a serious criminal case.

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

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