Vijay Shankar v. State of Haryana
Background
During a Holi night in 1995, the appellant was alleged to have fatally stabbed and attacked a man at a village poultry farm after an earlier quarrel over parking a cycle and drinking liquor on the farm. There was no eyewitness to the actual killing; the prosecution's case rested on motive, a "last seen together" sighting, an alleged extra-judicial confession, and recovery of a blood-stained knife and clothes. The trial court convicted the appellant of murder and house-trespass, and the Punjab and Haryana High Court upheld the conviction and life sentence.
Decision Breakdown
The Supreme Court closely re-examined each strand of circumstantial evidence, as is required when a conviction rests entirely on such evidence. It found the key "last seen" witness's account implausible: he claimed to have recognised the appellant from roughly 25 feet away in the middle of the night while searching for a lost buffalo, which the Court found improbable given his wealth and the circumstances. It also found the alleged extra-judicial confession unreliable, since it was made to a witness with no real standing and under suspicious circumstances. With the motive evidence weak and uncorroborated, the chain of circumstances did not point unerringly to the appellant's guilt, so the Court acquitted him and ordered his bail bonds discharged.
Lesson Learnt
A criminal conviction based only on circumstantial evidence requires every link in the chain of proof to be solid and free of reasonable doubt: if even one key piece (like an implausible eyewitness claim) is unreliable, the whole conviction can collapse on appeal.