In a significant verdict on January 24, the Supreme Court reversed the conviction of an accused in a 15-year-old murder case, highlighting the inadequacy of relying solely on suspicion. The Bench of Justices B.R. Gavai and Sandeep Mehta rejected the findings of both the High Court and the Trial Court, emphasizing the necessity of corroborated evidence to establish guilt.
The prosecution had alleged that the accused committed murder in 2009 using a dagger and later wrapped the body in a blanket. Recoveries, including a blood-stained dagger, were made at the accused’s instance. However, the prosecution failed to conclusively prove that the blood stains on the dagger belonged to the accused.
The trial court based its conviction on the similarity between pieces of blanket recovered from the crime scene and the place where the body was disposed of. The High Court affirmed the conviction, citing the accused’s failure to provide a satisfactory explanation during questioning.
Challenging the conviction, the accused argued against relying on suspicious recoveries as the sole basis for conviction. The Supreme Court concurred, asserting that suspicion, no matter how strong, cannot substitute proof beyond reasonable doubt. The court emphasized the prosecution’s duty to establish guilt with concrete evidence.
Examining the material evidence, the court dismissed the prosecution’s reliance on the Forensic Science Laboratory (FSL) report, which indicated human blood on the dagger but lacked a match with the deceased’s blood group.
The court ruled that the recovery of a blood-stained weapon alone cannot lead to conviction unless directly linked to the accused’s involvement in the murder. It criticized the prosecution for failing to meet the burden of proving guilt beyond a reasonable doubt.
Rejecting the High Court’s reliance on the accused’s inability to explain certain aspects under Section 313 Cr.P.C., the Supreme Court clarified that a non-explanation or false explanation cannot be an additional link in the chain of circumstances. It affirmed that such explanations could only reinforce guilt already established through proven circumstances.
In conclusion, the Supreme Court allowed the appeal, quashing the impugned judgment and order passed by the High Court, highlighting the paramount importance of concrete evidence in criminal convictions.
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