Yogesh v. The State of Haryana
Background
In 2004 a seven-year-old girl was abducted by two men on a motorcycle in Bahadurgarh, Haryana, and was later found murdered, with the post-mortem indicating sexual assault and death by strangulation and smothering. Eight persons were tried, and the trial court convicted four, Yogesh, Sumit, Pardeep and Anuj, of murder and conspiracy (though not of kidnapping or rape) based on the testimony of the victim's father and recovered items, and the Punjab and Haryana High Court upheld the conviction. Three of the four convicted men (Yogesh, Anuj and Pardeep) appealed to the Supreme Court.
Decision Breakdown
The Supreme Court found that the three persons projected as eyewitnesses were unreliable: two close relatives of the victim had turned hostile and expressly said the accused were not the men who took the child, and the father (the main prosecution witness) was not actually an eyewitness to the abduction itself and only came out after hearing noise. Applying the settled law on circumstantial evidence (from Sharad Birdhichand Sarda v. State of Maharashtra) that the chain of circumstances must be complete and consistent only with guilt, the Court held that recovery of some of the victim's belongings, without more, could not establish guilt beyond reasonable doubt. Since the prosecution's case left an incomplete and inconsistent chain of circumstances, the Court held the appellants were entitled to the benefit of doubt. The convictions and sentences were set aside and the appellants ordered released.
Lesson Learnt
In a case built entirely on circumstantial evidence, courts must ensure every link in the chain is firmly proved and points only to guilt; witnesses who turn hostile or whose testimony does not actually establish eyewitness knowledge cannot be used to fill gaps, and any reasonable doubt must benefit the accused.