BENCH COMPRISING OF JUSTICE D.A DESAI, JUSTICE RB MISRA

This case revolves around the question of circumstantial evidence and the burden of proof in criminal law. The appellant, Dudh Nath Pandey, was convicted for the murder of his cousin, Ram Prakash Pandey. The conviction was based on circumstantial evidence, and the Supreme Court was called upon to address key issues of admissibility and sufficiency of such evidence to uphold the conviction.

FACTS

Ram Prakash Pandey was killed on the night of August 6, 1970, in the house of Dudh Nath Pandey, allegedly after a quarrel between the two. The prosecution primarily relied on circumstantial evidence, including the recovery of blood-stained items and the behavior of the appellant. The prosecution argued that the accused had a motive arising from a family dispute over property. The appellant claimed innocence, alleging a conspiracy to falsely implicate him due to strained family relations.

ISSUES

1. Whether the circumstantial evidence presented by the prosecution was sufficient to establish guilt beyond a reasonable doubt.

2. Whether the burden of proof was properly discharged by the prosecution.

3. Whether the evidence met the legal standard required in a criminal case.

CONTENTIONS OF THE PETITIONERS

The appellant argued that there was no eyewitness to the crime, and the case was entirely based on circumstantial evidence, which was insufficient to prove guilt. Also claimed he was falsely implicated due to family disputes. Further contended that the prosecution's evidence was inconsistent and failed to establish a clear chain of circumstances.

CONTENTIONS OF THE RESPONDENT

The State argued that the circumstantial evidence, when taken together, clearly pointed to the guilt of the accused.The State highlighted the suspicious conduct of the accused, such as attempting to hide evidence, which indicated guilt. Further contended that the accused had a strong motive to commit the crime due to the ongoing property dispute.

COURT’S ANALYSIS

The Court reiterated the established principle that circumstantial evidence must form a complete chain, pointing unerringly to the guilt of the accused and ruling out any possibility of innocence. The Court also emphasized that the burden lies entirely on the prosecution to prove guilt beyond a reasonable doubt, especially in cases based on circumstantial evidence. It found gaps in the chain of evidence presented by the prosecution, including the absence of credible proof connecting the accused directly to the crime. Further held that while the accused may have had a motive, motive alone cannot form the basis of conviction without corroborating evidence.

CONCLUSION

The Supreme Court allowed the appeal, setting aside the conviction of Dudh Nath Pandey. The Court held that the prosecution failed to establish the guilt of the accused beyond a reasonable doubt due to the absence of a complete and unbroken chain of circumstantial evidence. The appellant was acquitted, reinforcing the principle that suspicion, however strong, cannot substitute for proof in criminal law.