Case Note & Summary
The Supreme Court allowed the criminal appeal filed by M Anoj @ Munna against his conviction under Sections 302 and 201 of the Indian Penal Code, 1860 for murder and causing disappearance of evidence -- The Trial Court and High Court had convicted the appellant based on the last seen theory and circumstantial evidence -- The Supreme Court found that the prosecution failed to establish a complete chain of circumstances pointing unequivocally to the appellant's guilt -- The medical evidence proved homicidal death but did not connect the appellant to the crime -- The last seen evidence was unreliable and uncorroborated -- The prosecution failed to prove motive and the evidence contained contradictions -- Applying the principles from Sharad Birdhichand Sarda case, the Court held that the chain of circumstances was incomplete and the appellant was entitled to benefit of doubt -- The conviction and sentence were set aside and the appellant was acquitted
Headnote
The Supreme Court allowed the criminal appeal and set aside the conviction of the appellant under Sections 302 and 201 of the Indian Penal Code, 1860 (IPC) -- The Court held that the prosecution failed to establish a complete chain of circumstantial evidence as required by the principles laid down in Sharad Birdhichand Sarda vs. State of Maharashtra -- The last seen theory alone was insufficient to sustain conviction without corroborative evidence -- The medical evidence established homicidal death but did not connect the appellant to the crime -- The prosecution failed to prove motive and the evidence suffered from contradictions -- The appellant was entitled to benefit of doubt -- The Court emphasized that circumstantial evidence must be wholly inconsistent with innocence and consistent only with guilt -- The judgment reaffirmed the five golden rules for appreciating circumstantial evidence
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Issue of Consideration: Whether the Trial Court and the High Court were correct in convicting the appellant solely on the basis of the theory of last seen together
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Final Decision
The Supreme Court allowed the appeal, set aside the conviction and sentence imposed by the Trial Court and affirmed by the High Court, and acquitted the appellant of all charges -- The appellant was directed to be released forthwith if not required in any other case
