The Supreme Court clarified that judicial members of Consumer Commissions are exempt from written exams. It upheld a five-year tenure and judicial majority in selection committees, while validating past appointments made before specific Limaye-I directives. The Court also mandated new rules from the Union of India, ensuring a permanent adjudicatory forum and expediting recruitment across states.
Facts Of The Case:
The prosecution’s case originated from an incident on April 4, 2016, around 11 a.m., when the informant’s son, Akash Garadia, along with Budhadeba Garadia (PW-1), Susanta Kusulia (PW-2), and the appellant/accused, went to a river to bathe. Subsequently, the appellant and Akash proceeded to a cashew field. When Akash and the appellant failed to return, PW-1 and PW-2 came back to the village. Upon inquiry from the informant (PW-3), PW-1 and PW-2 recounted the appellant’s evasive replies and threats if they disclosed his statements. The informant then questioned the appellant, who feigned ignorance. The next day, PW-3 discovered Akash’s dead body floating in the river, leading him to lodge an FIR alleging the appellant had murdered his son and disposed of the body. Based on this, a chargesheet was filed against the appellant under Sections 302 and 201 of the Indian Penal Code. The appellant pleaded not guilty, claiming false implication. The prosecution presented 19 witnesses and 10 documents. The Trial Court convicted the appellant, a decision subsequently affirmed by the High Court, primarily relying on “last seen together” evidence, recovery of a weapon, and motive.
Procedural History:
The case commenced with an FIR lodged by the informant (PW-3) on April 5, 2016, leading to Muniguda Police Station Case No. 37 of 2016 under Sections 302 and 201 IPC. Investigating Officer Lakshman Majhi (PW-19) conducted the investigation, culminating in a chargesheet filed against the appellant for the aforementioned offenses. Charges were formally framed, to which the appellant pleaded not guilty, claiming false implication. During the trial, the prosecution presented 19 witnesses and 10 documents, including a blood-stained stone. The appellant did not call any defense witnesses and, in his examination under Section 313 Cr.P.C., maintained his plea of false implication. Based on the evidence, the Trial Court found the appellant guilty of both charges and imposed a sentence, which was subsequently affirmed by the High Court.
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Court Observation:
The Supreme Court meticulously observed that in cases relying on circumstantial evidence, the prosecution bears the burden of proving each circumstance, forming a complete chain that points unerringly and exclusively to the accused’s guilt. Citing precedents, the Court reiterated that the “last seen together” theory, while relevant, constitutes a weak piece of evidence, insufficient on its own for conviction without strong corroborative material. Specifically, the Court noted the unreliability of the alleged motive, as it was introduced by a witness for the first time during trial without prior police record. Furthermore, it was observed that the weapon of offense was not recovered at the appellant’s instance, nor was any memorandum statement recorded from him, diminishing the probative value of the recovery. The chemical examination report, though indicating human blood on clothing and a stone, was deemed inconclusive due to the absence of blood group matching. Ultimately, the Court concluded that the cumulative circumstantial evidence, primarily resting on the “last seen together” theory, was insufficient to establish guilt beyond reasonable doubt, emphasizing that strong suspicion cannot substitute concrete proof.
Final Decision & Judgement:
In its final judgment, the Supreme Court, after reviewing the evidence and legal principles, set aside the impugned conviction and sentence imposed by both the High Court and the Trial Court. The appellant was acquitted of the charges under Sections 302 (murder) and 201 (causing disappearance of evidence of offense, or giving false information to screen offender) of the Indian Penal Code. The Court directed that the appellant be set at liberty if not required in any other case, and the appeal was allowed.
Case Details:
Case Title: Padman Bibhar Versus State of Odisha Citation: 2025 INSC 751 Criminal Appeal No.: Criminal Appeal No. of 2025 Date Of Judgement: May 21, 2025 Judges/Justice Name: Justice Sanjay Karol and Justice Prashant Kumar Mishra
Download The Judgement Here