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Mehtab v. State of Uttarakhand

Criminal Appeal · 2026 INSC 578Decided 27 May 2026
Crl.A. No.-001342-001343 - 2018
Justice Vikram Nath · Justice Sandeep Mehta · Justice Vijay Bishnoi

Background

A 55-year-old woman, Munni Devi, went missing while grazing goats in a forest in Uttarakhand in December 2012 and was later found dead, having allegedly been raped and murdered. The trial court convicted the appellants (Mehtab and a co-accused) under the IPC and the SC/ST Act based on circumstantial evidence ("last seen together" testimony, disclosure statements, recoveries, and forensic reports) and sentenced them to death. The Uttarakhand High Court partly allowed their appeal (acquitting them of the SC/ST Act charge) but confirmed the conviction and death sentence for murder and rape. The appellants then approached the Supreme Court by special leave.

Decision Breakdown

The Supreme Court found serious infirmities in the prosecution's case: the "last seen together" evidence and eyewitness identification were unreliable, the recoveries of incriminating articles suffered from broken chain of custody and procedural irregularities, and the forensic (FSL) evidence of semen traces was not corroborated by any DNA profiling linking it to the accused. The Court also noted medical evidence that one accused was physically incapable of sexual intercourse, undermining the prosecution's theory of motive. Holding that in a case built entirely on circumstantial evidence, the chain of circumstances must be complete and point unerringly to guilt while ruling out innocence, the Court concluded the prosecution had failed to meet this standard.

Lesson Learnt

A criminal conviction, especially one carrying the death penalty, cannot rest on a circumstantial chain riddled with gaps in evidence handling, uncorroborated forensic findings, and unproven motive; courts must insist that every link in such a chain be proved beyond reasonable doubt before depriving a person of life or liberty.

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

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