Pattu Rajan v. The State of Tamil Nadu
Background
A hotel-chain proprietor developed an obsession with a married woman (PW1) and, after an earlier abduction attempt, enlisted the appellants to help eliminate her husband, Santhakumar, so he could marry her. The victim and his wife were lured to a temple, abducted by the accused, and the husband was later killed and his body disposed of in a forest area, later recovered based on one accused's confession and identified through forensic means including facial superimposition. The trial court convicted the accused under Sections 364, 304 Part I and 201 IPC, and the Madras High Court enhanced the conviction to Section 302 (murder); the convicts appealed to the Supreme Court challenging the reliability of the "last seen" evidence, the recovery of the body, and procedural objections about a second FIR.
Decision Breakdown
The Supreme Court held that the consistent and credible testimony of the prosecution's key eyewitnesses, corroborated by recovery of the body at the instance of one accused, forensic identification, and circumstantial evidence such as fuel-purchase records tracing the vehicle's route, proved the prosecution's case beyond reasonable doubt. The Court rejected the defence's procedural objections, holding that the "last seen" circumstance had in fact been put to the accused during their Section 313 examination, and that the accused's failure to offer any explanation for the deceased's fate after being last seen with them gave rise to an adverse inference. Finding no infirmity in the concurrent findings of the Trial Court and High Court, the Supreme Court dismissed all the appeals and upheld the convictions.
Lesson Learnt
In a case built on circumstantial evidence, the "last seen together" doctrine shifts the burden onto the accused to explain what happened afterward; an accused's silence or failure to give a plausible explanation can itself become an incriminating link that supports conviction.