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Ravi Sharma vs. State (Government of N.C.T. of Delhi) & Anr.

Criminal Appeal · 2022 INSC 699Decided 11 Jul 2022
Criminal Appeal Nos. 410-411 of 2015
Abhay S. Oka · M.M. Sundresh

Background

The accused was tried for the murder of a friend after a body was found in 2011. The Trial Court acquitted him, giving him the benefit of the doubt because the alleged motive was not proved, the "last seen" theory was doubtful, and the recovery of a firearm under Section 27 of the Evidence Act (based on the accused's disclosure) was found suspicious, given inconsistencies and the absence of independent witnesses. The Delhi High Court reversed this acquittal and convicted the accused, relying on the alleged motive together with the recovery evidence and a ballistic report, leading to this appeal to the Supreme Court.

Decision Breakdown

The Supreme Court reaffirmed the well-settled principles for cases based on circumstantial evidence: the circumstances must be firmly established, form a complete chain pointing unerringly to guilt, and be inconsistent with any hypothesis of innocence. It found the recovery evidence deeply flawed (major contradictions among witnesses about how and where the recovery took place, and no independent witnesses despite many bystanders being present), and noted the ballistic report was inconclusive as to whether the fatal bullet came from the accused's firearm. Applying the principle that an accused enjoys a "double presumption" of innocence once already acquitted by a trial court, the Supreme Court held the High Court should have been slower to reverse a reasoned acquittal, found no sufficient link establishing guilt, set aside the High Court's conviction, and restored the trial court's acquittal.

Lesson Learnt

In cases resting solely on circumstantial evidence, mere suspicion, however strong, cannot substitute for a complete, unbroken chain of proven facts pointing exclusively to guilt; and appellate courts should be cautious before overturning a trial court's acquittal, since the accused benefits from a "double presumption" of innocence once acquitted after a full trial.

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

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