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Manharan Rajwade vs The State of Chhattisgarh

Not available · 2024 INSC 560Decided 25 Jul 2024
Not available
Justice Abhay S. Oka · Justice Prashant Kumar Mishra · Justice Augustine George Masih

Background

The appellant was convicted of murdering his wife and sentenced to life imprisonment. The prosecution's case rested entirely on the "last seen together" theory: that since the couple were together shortly before her death, the burden shifted to the husband to explain what happened. Two prosecution witnesses were examined, but both were declared hostile at trial.

Decision Breakdown

The Supreme Court closely examined the hostile witnesses' testimony and found that, contrary to the prosecution's theory, the evidence actually showed the wife had already died before the appellant returned home: one witness stated she found the deceased already unresponsive around 5 p.m., while the appellant only came back around 7 p.m. Since there was no proof that the couple were together shortly before death, the "last seen together" presumption could not be invoked to shift the burden to the appellant under Section 106 of the Evidence Act. With the prosecution's only circumstance found to be unproven, the Court held the murder charge was not established, set aside the conviction, and ordered the appellant's acquittal and release.

Lesson Learnt

A conviction based on circumstantial evidence like "last seen together" collapses if the prosecution's own evidence contradicts the timeline it relies on. Courts must scrutinise even hostile witness testimony carefully rather than accept the prosecution's theory at face value.

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

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