[ Court Doc ]   Evidence >> Criminal Law   |   Murder Homicide >> Criminal Law  

On May 30, 2025, the Supreme Court of India delivered a crucial judgment in the case of Chetan v/s The State of Karnataka, upholding the conviction of the appellant for murder and other related offenses. The ruling by Justices Surya Kant and Nongmeikapam Kotiswar Singh underscored the robustness of circumstantial evidence when it forms a complete and unbroken chain, even in the absence of direct eyewitness testimony.

Background of the Case:

The appellant, Chetan, had been convicted by the Fast Track Court-II & Additional Sessions Judge, Belgaum, for murder under Section 302 of the Indian Penal Code (IPC), misappropriation of property under Section 404 IPC, and offenses under Sections 25 and 27 of the Arms Act, 1959. The High Court of Karnataka, Circuit Bench at Dharwad, had affirmed this conviction in its judgment dated December 6, 2010. Chetan subsequently appealed to the Supreme Court.

Appellant's Contentions and Legal Arguments:

Chetan's counsel presented several arguments challenging his conviction:

• Lack of Eyewitness: It was emphasized that the case was based solely on circumstantial evidence, with no direct eyewitness to the murder.
• Incomplete Chain of Circumstances: The defense contended that the chain of circumstantial evidence relied upon by the prosecution was not complete and did not unequivocally point towards Chetan's guilt.
• Motive Not Proven: The prosecution allegedly failed to establish a clear and convincing motive for the murder.
• Questionable Recoveries: The recovery of the deceased's Nokia mobile phone and a gold chain, both crucial pieces of evidence, was challenged. The defense argued that the mobile phone's recovery was suspicious as it was found in a public place where it could have been planted, and the gold chain's recovery suffered from inconsistencies in witness statements.
• Voluntary Statement: The defense also questioned the validity of Chetan's voluntary statement and the subsequent recoveries made based on it, arguing that without a proper chain of evidence, these could not conclusively prove guilt.
• Benefit of Doubt: Given the alleged gaps and inconsistencies, the appellant sought the benefit of doubt.

Supreme Court's Analysis and Verdict:

The Supreme Court meticulously re-examined the evidence and the findings of the lower courts. The Court reiterated the established principles governing convictions based on circumstantial evidence: the circumstances must be conclusively established, they must be consistent only with the hypothesis of guilt, and they must exclude every other reasonable hypothesis of innocence.

After a thorough review, the Supreme Court found no infirmity in the appreciation of evidence by the Trial Court and the High Court. The Court noted that the evidence, taken collectively, formed a complete chain that pointed unerringly to the appellant's guilt.

Specifically, the Court made the following observations:

• Recovery of the Gold Chain: The recovery of the deceased's gold chain from Chetan's person was deemed a strong piece of evidence, even if there were minor discrepancies in witness statements regarding the exact time or place of its display. The core fact of its recovery from the accused remained unchallenged.
• Recovery and Use of the Weapon: Evidence related to the recovery and use of the firearm by Chetan was also considered crucial and was upheld.
• Circumstantial Chain: The Court affirmed that despite the absence of an eyewitness, the cumulative effect of the established circumstances, including the possession of the deceased's belongings and the weapon used, effectively closed the chain of evidence against the appellant.

While the Supreme Court upheld the convictions under Sections 302 (murder) and 25 and 27 of the Arms Act, it partially set aside the conviction under Section 404 IPC (misappropriation of property) specifically concerning the recovery of the Nokia Mobile Phone. The Court granted the appellant the benefit of doubt regarding this particular recovery, implying that the evidence for the mobile phone was not as conclusively established as the other circumstances.

Consequently, the appeal was dismissed, and the impugned judgment of the High Court of Karnataka was largely upheld. The bail bonds furnished by the appellant were cancelled, and he was directed to surrender before the Trial Court forthwith to undergo the remaining period of his sentence.

This judgment reinforces the judiciary's approach to circumstantial evidence, emphasizing that its strength lies in the unbroken chain of facts that, when combined, lead to an inescapable conclusion of guilt. It also demonstrates the Court's willingness to meticulously scrutinize individual pieces of evidence, providing relief where reasonable doubt persists on specific charges while maintaining convictions where the evidence is overwhelming.

Section 302., Indian Penal Code - 1860  

Indian Penal Code, 1860  

Section 25, Arms Act - 1959  

Section 27, Arms Act - 1959  

Arms Act, 1959