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Navaneethakrishnan v. The State by Inspector of Police

Criminal Appeal · 2018 INSC 343Decided 16 Apr 2018
Criminal Appeal No. 1134 of 2013
Justice A.K. Sikri · Justice R.K. Agrawal

Background

The appellants were convicted by a Fast Track Court in Salem, Tamil Nadu, and that conviction was upheld by the Madras High Court, for the murder of a taxi driver, John Bosco, and his friend Madhan in 2008, allegedly to rob a vehicle. The prosecution's case rested entirely on circumstantial evidence: the "last seen together" theory, recoveries of a mobile phone and a camera said to belong to the deceased, and confessional statements made by the accused to the police leading to those recoveries.

Decision Breakdown

The Supreme Court found that the lower courts had wrongly relied on portions of the accused's custodial statements that amounted to confessions (inadmissible under Section 26 of the Evidence Act) rather than only the narrow part admissible under Section 27 as leading to discovery of a new fact. It further found that the prosecution had failed to actually prove that the recovered mobile phone and camera belonged to the deceased, and that other recovered items (a different phone and a motorbike) had no proven connection to the crime at all. With these links removed, the chain of circumstantial evidence was incomplete and did not exclude every hypothesis other than the guilt of the accused. The Court therefore set aside the conviction and acquitted the appellants, ordering their release if not wanted in any other case.

Lesson Learnt

A conviction based purely on circumstantial evidence can stand only if every link in the chain is independently and reliably proved and the chain as a whole points unerringly to guilt with no other reasonable explanation; gaps in proving recovered items actually belong to the victim, or over-reliance on inadmissible parts of a custodial confession, can be fatal to the prosecution's case.

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

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