This Supreme Court judgment underscores the stringent standards for conviction based on circumstantial evidence. It holds that the prosecution must establish a complete and unbroken chain of circumstances, excluding every hypothesis of innocence. Where gaps exist or alternative possibilities emerge, the benefit of doubt must be accorded to the accused, leading to acquittal if guilt is not proven beyond reasonable doubt.
Facts Of The Case:
An 85-year-old woman, living alone in Coimbatore, was found murdered in her home on the morning of December 19, 2016. She had been strangled with a towel, sexually assaulted, and her two gold bangles were missing. The prosecution’s case relied on circumstantial evidence against the appellant, Mohamed Sameer Khan. Key points included that the appellant was seen near the deceased’s compound around 2:45 a.m. by a witness (PW-5) and had left the house where he was staying as a guest around 3:00 a.m. on the night of the murder, appearing perturbed. Days later, he was allegedly arrested after jumping from an over-bridge upon seeing police. In the hospital, he purportedly confessed and produced the stolen bangles. However, the defense contested this, alleging the appellant was tortured and the bangles were planted. Critically, there was no forensic evidence (fingerprints, DNA) linking him to the crime scene, the key witness who was with him just before the incident was never examined, and the informant who identified him to police was never disclosed.
Procedural History:
The procedural history of this case began with the appellant’s conviction by the Second Additional Sessions Judge, Special Court for Bomb Blast Cases, Coimbatore, on November 17, 2017, under Sections 302, 449, 376, and 394 of the Indian Penal Code. The conviction and sentence were subsequently appealed before the High Court of Judicature at Madras, which upheld the trial court’s judgment in its ruling dated October 28, 2021. The appellant then exercised his final right of appeal by filing a criminal appeal before the Supreme Court of India. The Supreme Court, in its judgment dated October 29, 2025, allowed the appeal, set aside the convictions from both lower courts, and acquitted the appellant, ordering his immediate release.
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Court Observation:
The Supreme Court observed critical flaws in the prosecution’s circumstantial evidence chain. It noted the absence of forensic links—such as fingerprints, DNA, or material evidence—connecting the appellant to the crime scene or the deceased. The Court found the testimonies placing the appellant near the scene to be insufficient and non-specific, and highlighted the investigation’s failure to examine Marcus, a crucial companion of the appellant around the time of the offence, as a serious infirmity. Furthermore, it raised grave doubts regarding the recovery of stolen bangles and the appellant’s arrest, citing potential police planting of evidence and undisclosed informants. The Court concluded that the evidence presented left room for reasonable hypotheses of innocence and failed to form an unbroken chain pointing solely to the appellant’s guilt, thereby mandating acquittal.
Final Decision & Judgement:
The Supreme Court allowed the appeal, setting aside the appellant’s convictions under Sections 302, 449, 376, and 394 of the Indian Penal Code. The Court held that the prosecution failed to prove the appellant’s guilt beyond reasonable doubt, as the circumstantial evidence was incomplete, left gaps, and permitted other reasonable hypotheses of innocence. Consequently, the appellant, Mohamed Sameer Khan, was acquitted of all charges and ordered to be released forthwith from custody.