Taher Vajiyuddin Rangwala v. State of Gujarat
Background
The appellants were convicted of murdering a friend, whose body was found in a river. The prosecution's case was that the deceased had been taken from home early one morning under the pretext of going to play volleyball, never returned, and was later found drowned. According to a witness (the deceased's brother), the accused had confessed inside a car that they had gone swimming with the deceased, he accidentally drowned, and they panicked, fled the scene, and went to watch a movie instead of raising an alarm or seeking help.
Decision Breakdown
The Supreme Court examined the chain of circumstantial evidence relied upon by the trial court and High Court to sustain the murder conviction and found that none of the incriminating circumstances were actually proved to the standard required to rule out every reasonable hypothesis except guilt. The Court found the version of accidental drowning more probable than deliberate murder on the evidence on record. It held that while the accused's conduct, fleeing the scene and going to watch a movie instead of trying to rescue their drowning friend or informing anyone, was reprehensible, this alone could not establish the offence of murder. Finding the hypothesis of innocence not adequately displaced, the Court reversed the conviction and acquitted the accused, ordering their release if not wanted in any other case.
Lesson Learnt
In cases built entirely on circumstantial evidence, every link in the chain must be proved beyond reasonable doubt and must be consistent only with the guilt of the accused: morally reprehensible conduct, like fleeing a scene or failing to help, is not by itself proof of a more serious crime like murder.