Supreme Court found material contradictions and inconsistencies in the prosecution’s case. The delay in witness statements was unexplained, raising doubts. The ballistic report did not conclusively link the firearm to the crime. The prosecution failed to establish guilt beyond reasonable doubt. The conviction was set aside, and the appellant was ordered to be released forthwith.

Acts and Sections Discussed:

• Constitution of India, 1950 – Article 136 – Special Leave to Appeal
• Indian Penal Code, 1860 – Section 302 – Punishment for Murder – Section 109 – Abetment of Offence
• Code of Criminal Procedure, 1973 – Section 374 – Appeal Against Conviction – Section 313 – Examination of the Accused

Subjects:

Appeal Against Conviction – Murder – Abetment – Circumstantial Evidence – Delay in Witness Statements – Ballistic Report – Benefit of Doubt – Property Dispute – Caste-Based Opposition – Recovery of Firearm – Burden of Proof

Facts:

a. Nature of the Litigation – Criminal appeal challenging the High Court’s decision affirming the conviction under Section 302 and Section 109 of the Indian Penal Code, 1860.
b. Who Moved the Court and for What Remedy? – Appellant, Siba Nial @ Trilochan, sought reversal of conviction and release from custody.
c. Reason for Filing the Case – The appellant was convicted for the murder of Dhaneswar Kata and Nirupama Kata based on circumstantial evidence and alleged recovery of a firearm.
d. What Had Already Been Decided? – The Trial Court convicted the appellant, which was affirmed by the High Court. The Supreme Court re-examined the case based on the appellant's challenge.

Issues:

• Whether the prosecution proved guilt beyond reasonable doubt?
• Whether the delay in witness statements affected credibility?
• Whether the forensic and ballistic reports sufficiently connected the appellant to the crime?
• Whether motive alone could justify conviction in the absence of direct evidence?

Submissions/Arguments:

• Appellant’s Arguments:
  • No direct evidence against the accused.
  • Delay in witness statements raises doubts about credibility.
  • Ballistic report did not conclusively link the recovered firearm to the crime.
  • Alternative motive of caste-based opposition not adequately considered.
• State’s Arguments:
  • Eyewitnesses placed the appellant near the crime scene.
  • Recovery of firearm and disclosure statement supported conviction.
  • Motive established through property dispute.

Ratio:

• Conviction must be based on evidence establishing guilt beyond reasonable doubt.
• Unexplained delay in witness statements weakens the prosecution’s case.
• Circumstantial evidence must form a complete chain linking the accused to the crime.
• Motive alone is insufficient to sustain conviction in the absence of conclusive proof.