Chetan vs. State of Karnataka
Criminal Appeal No. 1568 of 2013
Decided by: Justice Nongmeikapam Kotiswar Singh
Supreme Court of India | Date of Judgment: May 17, 2024
Case Summary:
In this appeal, Chetan, the accused, challenged his conviction under Section 302 of the Indian Penal Code (IPC) for the alleged murder of a young woman. The trial court and the High Court of Karnataka both upheld his conviction, relying heavily on circumstantial evidence, including last-seen theory and alleged motive.
However, on appeal to the Supreme Court, the defence argued that the prosecution failed to establish a complete chain of circumstances pointing conclusively to the guilt of the accused. There were significant gaps in evidence, including lack of motive, no eyewitnesses, and failure to recover any incriminating material connecting Chetan to the crime scene.
⚖️ Key Observations by the Supreme Court:
- The Court reiterated that conviction based solely on circumstantial evidence must satisfy the well-established test: the chain of circumstances must be complete and point unerringly to the guilt of the accused.
- In this case, the Court found the last-seen theory weak, and no recovery or forensic evidence had been made.
- Suspicion, however strong, cannot replace proof. The gaps in the prosecution’s case created reasonable doubt.
🏛️ Final Judgment:
The Supreme Court allowed the appeal, setting aside the conviction and sentence. Chetan was acquitted of all charges under Section 302 IPC.
“The benefit of the doubt must go to the accused when the prosecution fails to establish a complete chain of circumstances. We, therefore, hold that the conviction cannot be sustained.”
Significance:
This ruling emphasizes the principle that in criminal trials, the burden of proof lies entirely on the prosecution, and circumstantial evidence must be compelling and conclusive to secure a conviction.