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Malti Sahu vs. Rahul & Anr.

Criminal Appeal · 2022 INSC 702Decided 11 Jul 2022
Criminal Appeal No. 471 of 2022
M.R. Shah · B.V. Nagarathna

Background

In December 2011 in Chandigarh, a mother returned home to find her two children, 17-year-old Kavita Sahu and her younger brother Gaurang Sahu, murdered with cut throats. The accused, Rahul, was traced through a witness who had seen him with the children shortly before the incident, and was later arrested; a blood-stained shawl and clothes were recovered based on his disclosure statement, along with a knife found broken into three pieces at the crime scene that a shopkeeper testified he had sold to the accused. The Trial Court convicted Rahul for both murders under Section 302 IPC and sentenced him to life imprisonment, but the High Court acquitted him on appeal, holding that the prosecution had not proved a complete chain of circumstantial evidence. The victims' mother and the State then appealed to the Supreme Court against the acquittal.

Decision Breakdown

The Supreme Court held that the High Court had committed a serious error and its findings were perverse, having failed to properly appreciate the evidence the Trial Court had relied upon. The Court found the chain of circumstances complete and convincing: proof that the accused purchased the murder weapon, forensic evidence matching blood on the recovered shawl to both the accused and the deceased, an unexplained fresh injury on the accused's hand consistent with using a sharp weapon, and partial corroboration of motive (harassment of the deceased) even from a witness who had turned hostile. Because the accused could not explain these incriminating circumstances, the Court restored the Trial Court's conviction and life sentence, allowing the appeals and directing the accused to surrender to serve his sentence.

Lesson Learnt

A conviction can rest entirely on circumstantial evidence provided the chain of facts (motive, recovery of the weapon linked to the accused, forensic matches, and an unexplained injury) is complete and points only to the guilt of the accused; and an appellate court cannot overturn such a conviction by cherry-picking gaps in the evidence without properly engaging with the trial court's full reasoning.

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

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