Nizam & Anr. v. State of Rajasthan
Background
The deceased, Manoj, was a helper on a truck; when his own truck and its driver were detained by police after a quarrel, he was asked to travel onward with his money to the truck owner in a second truck driven by the appellants, Nizam and his companion. Three days later, Manoj's body was found in a field under suspicious circumstances, and the appellants were convicted of his murder and sentenced to life imprisonment, a conviction that was upheld by the Rajasthan High Court based essentially on the "last seen together" circumstance (that the appellants were the last people seen with Manoj before his death).
Decision Breakdown
The Supreme Court held that where the time gap between the deceased being "last seen" with the accused and the discovery of the body is substantial, here, about three days, the last-seen theory alone becomes unsafe to rely on unless corroborated by other evidence, since the possibility of intervening events or other persons cannot be ruled out. The Court noted serious gaps in the investigation: no recovery of the murder weapon or the allegedly stolen money, no identification of the body, an unexplained injury, and a false complaint by a key prosecution witness. Since the chain of circumstantial evidence was not complete and more than one inference was reasonably possible, the appellants were entitled to the benefit of the doubt. The Court therefore set aside the conviction under Sections 302 and 201 IPC, allowed the appeal, and ordered the appellants to be released.
Lesson Learnt
In cases built on circumstantial evidence, "last seen together" is not enough by itself to convict someone of murder: the longer the gap before the body is found, the more the prosecution needs solid, independent corroborating evidence, or the accused must get the benefit of the doubt.