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Rohit Jangde v. State of Chhattisgarh

Criminal Appeal · 2026 INSC 162Decided 17 Feb 2026
Crl.A. No.-000689-000689 - 2026
Justice Sanjay Kumar · Justice K. Vinod Chandran

Background

The appellant was convicted of murdering his six-year-old stepdaughter and sentenced by the trial court, a conviction affirmed by the Chhattisgarh High Court, based on three circumstances: a "last seen together" account from a neighbour, burnt bone remnants recovered on the accused's disclosure, and a DNA match between the biological parents and remains found in a canal. The Supreme Court noted the investigation was seriously flawed, including apparent interpolation of dates on the arrest/court-surrender memo that cast doubt on when the accused was actually taken into custody relative to the disappearance.

Decision Breakdown

The Court found that the recovery of bone remnants on the accused's information, since he was not in police custody when he gave it, could only be treated as weak corroborative evidence under Section 8 of the Evidence Act (not a formal disclosure under Section 27), and could not by itself sustain a conviction. It also noted the DNA match was only established for some remains (vertebrae and teeth from the canal), not the skull or the remains recovered from the field, and that no time of death could be fixed since the body itself (corpus delicti) was never definitively recovered. Combined with serious doubts about the timeline of the accused's arrest and the prosecution's failure to explain a long, unexplained delay before even reporting the child missing, the Court held the chain of circumstantial evidence did not exclude every other reasonable hypothesis of innocence. The conviction was set aside and the accused was ordered released, while the Court separately noted its appreciation for how the State's own counsel had candidly exposed the investigation's shortcomings.

Lesson Learnt

A conviction based on circumstantial evidence must form an unbroken chain pointing only to guilt; procedural lapses in the investigation such as unexplained custodial timelines and incomplete forensic matching can create reasonable doubt sufficient to overturn even a conviction upheld by two lower courts.

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

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