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Raja Khan v. State of Chhattisgarh

Criminal Appeal · 2025 INSC 167Decided 7 Feb 2025
Crl.A. No.-000070-000070 - 2025 (Arising out of SLP (Crl.) No. 14411 of 2024)
Justice Sanjay Karol · Justice Manmohan

Background

The appellant was convicted by a trial court, and the conviction affirmed by the Chhattisgarh High Court, for the murder of one Neeraj Yadav, who had gone missing in November 2013 and was later found dead in a stone quarry pond. The prosecution's case rested entirely on circumstantial evidence: a disclosure statement allegedly made by the appellant while in police custody that led to recovery of a blood-stained stone and an axe (gandasa), recovery of the deceased's gold chains from the appellant's rooftop, and testimony that the appellant was "last seen" with the deceased shortly before he disappeared.

Decision Breakdown

The Supreme Court closely scrutinised the two key panch witnesses to the recovery and found serious, unresolved inconsistencies: one witness admitted he signed seizure papers at the police station without reading them and never actually saw the appellant point out the hidden items, while the diver who recovered the stone and weapon said he acted purely on police instructions, not the appellant's disclosure. The Court also found the identification parade for the gold chains unreliable, and the "last seen" testimony uncorroborated by other witnesses. Applying the settled five-point test for circumstantial evidence cases (from Sharad Birdhichand Sarda v. State of Maharashtra), that the chain of proved facts must exclude every hypothesis except guilt, the Court held the prosecution had failed to establish an unbroken, reliable chain of evidence. The conviction was set aside and the appellant was ordered released, given the benefit of the doubt.

Lesson Learnt

A conviction built on circumstantial evidence, recoveries and "last seen" testimony in particular, cannot stand if the manner of recovery is procedurally doubtful (e.g., paperwork signed at a police station rather than at the scene, or witnesses who never actually saw the accused point anything out); the law requires the prosecution's chain of proof to leave no reasonable alternative explanation.

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

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