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Murugan v. The State rep. by the Inspector of Police

Criminal Appeal · 2025 INSC 446Decided 4 Apr 2025
Crl.A. No.-003318-003318 - 2023
Justice Abhay S. Oka · Justice Ahsanuddin Amanullah · Justice Augustine George Masih

Background

A police constable was killed while chasing suspected sand smugglers, including the appellant, in a tractor-trailer at night. The trial court convicted the appellant and a co-accused of murder based on an alleged eyewitness, an extra-judicial confession by other co-accused, and a "last seen" witness, sentencing them to life imprisonment; the Madras High Court upheld the appellant's conviction while acquitting other co-accused of related charges.

Decision Breakdown

The Supreme Court found that the prosecution's key evidence had already crumbled. The High Court itself had disbelieved the eyewitness and the extra-judicial confession as unreliable, and the "last seen" witness had inexplicably delayed reporting what he saw for 17 days despite knowing the deceased and attending his postmortem. The FIR itself was presented to the magistrate many hours late without credible explanation, casting further doubt on the case. With the chain of circumstantial evidence broken and no single conclusive link connecting the appellant to the killing (beyond recovered slippers and a spanner), the Court held the prosecution had not proven guilt beyond reasonable doubt and acquitted the appellant, ordering his release.

Lesson Learnt

In cases built on circumstantial evidence, a conviction cannot stand if the chain of proof has gaps or contradictions. Courts must set aside a conviction and give the accused the benefit of the doubt when key prosecution witnesses are themselves found unreliable, even if some physical evidence remains.

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

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