The Supreme Court of India, overturned the appellant’s conviction for charges under Sections 302, 364, 384, and 201 of the IPC. The Court found critical lapses in the prosecution's evidence, including failure to establish motive, lack of credible proof regarding skeletal remains, and the unreliability of DNA evidence. Based on these deficiencies, the Court acquitted the appellant, emphasizing the principle that circumstantial evidence must form a complete chain excluding all hypotheses of innocence.

1. Background and Charges:

• Appellant (A1) convicted for murder, abduction, extortion, and destruction of evidence under Sections 302, 364, 384, and 201 IPC.
• Co-accused (A2 and A3) acquitted by the High Court; trial court's conviction against the appellant affirmed earlier.

2. Prosecution's Allegations:

• Alleged extra-marital affair between the deceased, K. Nagesh, and appellant's wife fueled animosity.
• Appellant purportedly abducted, murdered, and concealed the body of the deceased.

3. Key Evidence Presented:

• Alleged skeletal remains recovered on appellant’s disclosure.
• DNA profiling linking skeletal remains to the deceased's mother.
• Motive linked to an illicit affair and subsequent threats during a village panchayat.

4. Defense Submissions:

• Lack of evidence proving motive, as key witnesses (deceased's parents and wife of appellant) did not corroborate the alleged affair.
• Disclosure and recovery under Section 27 IEA were not proved as per legal standards.
• Skeletal remains and DNA profiling lacked proper procedural substantiation.

5. Supreme Court’s Analysis:

• Motive: No evidence supporting the alleged affair, with prosecution witnesses denying its existence.
• Recovery and Disclosure: Investigation failed to establish the accused's role in identifying the crime scene or in leading to the skeletal remains' recovery.
• DNA Profiling: Procedural lapses in collecting and verifying blood samples rendered DNA evidence inadmissible.

6. Conclusion and Judgment:

• Prosecution failed to establish the chain of circumstantial evidence beyond doubt.
• Appellant acquitted of all charges, highlighting procedural deficiencies and reliance on unproven links.

Acts and Sections Discussed:

1. Indian Penal Code, 1860 (IPC):

   • Section 302: Punishment for Murder.
   • Section 364: Kidnapping or Abducting in order to Murder.
   • Section 384: Punishment for Extortion.
   • Section 201: Causing Disappearance of Evidence.

2. Indian Evidence Act, 1872 (IEA):

   • Section 27: Admissibility of Statements Leading to Discovery.

3. Code of Criminal Procedure, 1973 (CrPC):

   • Section 313: Accused's Statement during Trial.

Ratio Decidendi:

In cases based purely on circumstantial evidence, every link in the chain must be conclusively established. The failure to prove disclosure, motive, and recovery weakens the prosecution’s case, mandating acquittal under the benefit of the doubt.

Subjects:

Criminal Law, Circumstantial Evidence, Procedural Lapses, Benefit of Doubt.

Indian Penal Code, Acquittal, DNA Evidence, Circumstantial Evidence.