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Ravishankar Tandon vs. State of Chhattisgarh

Not available · 2024 INSC 299Decided 10 Apr 2024
Not available
Justice B.R. Gavai · Justice Sandeep Mehta

Background

In December 2011, a young man went missing in Chhattisgarh, and after a search, police interrogated four suspects on suspicion, who allegedly disclosed that they had strangled the victim and dumped his body in a pond. Based on their memorandum statements under Section 27 of the Evidence Act, police recovered the body, and all four were tried, convicted of murder, and sentenced by the trial court, with the Chhattisgarh High Court upholding the convictions in 2013 and 2023 (dismissing their appeals).

Decision Breakdown

The Supreme Court scrutinised the prosecution's reliance on the accused's statements leading to "discovery" of facts under Section 27 of the Evidence Act, the only real evidence connecting them to the crime, and found the evidence badly deficient. The investigating officer's testimony did not actually establish what specific information the accused gave that led to discovery of the body, nor did it clearly explain how or where the body was found as a result of their statements. Since the chain of circumstantial evidence must be complete and point unerringly to guilt with no other possible explanation, and the prosecution failed to establish this here, the Court held the conviction could not stand. It quashed the judgments of both the trial court and the High Court and ordered the appellants acquitted and released.

Lesson Learnt

In cases built on circumstantial evidence, every link in the chain, including exactly what an accused person disclosed and how it led to recovery of evidence, must be proven with precision; vague or incomplete police testimony about such disclosures is not enough to sustain a murder conviction.

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

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