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Raju @ Rajendra Prasad vs State of Rajasthan

Criminal Appeal · 2022 INSC 983Decided 19 Sept 2022
Criminal Appeal No. 1559 of 2022
M.R. Shah · Krishna Murari

Background

The deceased's body was found hanging from a tree after he had gone to his in-laws' house to bring back his wife, Suman Devi, and children amid marital discord. The complainant (the deceased's brother) alleged that Suman Devi, who was said to be having an illicit relationship with co-accused Raju @ Rajendra Prasad, along with her parents and brother, had conspired to murder the deceased and stage it as suicide. The trial court convicted Suman Devi and Raju under Section 302 read with Section 34 IPC (murder with common intention) largely based on the testimony of the deceased's young daughter and Suman Devi's sister, sentencing them to life imprisonment. The Rajasthan High Court upheld the conviction, and the accused appealed to the Supreme Court.

Decision Breakdown

The Supreme Court noted the case rested entirely on circumstantial evidence, with no direct evidence of the accused's involvement, and reiterated the settled legal test that such evidence must form a complete, unbroken chain pointing exclusively to the accused's guilt and excluding every other reasonable hypothesis, including innocence. Examining the "star witness", the deceased's daughter, the Court found that she had testified only that there had been a quarrel and that her grandmother took her father to sleep in a room, but had explicitly stated in cross-examination that she had not seen anyone beating her father. There was no evidence that the accused were last seen with the deceased or of what happened after he went to sleep. Since the prosecution failed to establish a complete chain of circumstances proving guilt beyond the hypothesis of innocence, the Supreme Court held the conviction unsustainable, quashed it, acquitted both appellants, and ordered their release.

Lesson Learnt

A criminal conviction based purely on circumstantial evidence cannot stand unless the proven circumstances form a complete and unbroken chain that excludes every reasonable possibility other than the accused's guilt: suspicion, motive, or even the testimony of a key witness who did not actually witness the crime, is not enough.

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

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