The Supreme Court of India reaffirmed a cornerstone of the legal system: the principle that convictions must be based on concrete evidence rather than mere suspicion. This landmark decision came as the apex court acquitted a murder accused who had previously been found guilty by both the Trial Court and the Chhattisgarh High Court.

The case revolved around the murder of Shiva alias Sanwar in 2009, with the prosecution alleging that the accused, Naykar, had brutally stabbed the victim multiple times before attempting to dispose of the body. Despite the serious nature of the charges and the conviction handed down by lower courts, the Supreme Court stressed the importance of adhering to the highest standards of proof in criminal cases.

In its judgment, the Bench comprising Justice B.R. Gavai and Justice Sandeep Mehta underscored that conviction cannot rest solely on suspicion; rather, it is incumbent upon the prosecution to establish the guilt of the accused beyond all reasonable doubt. Quoting precedent, the Court emphasized that the burden of proof lies squarely on the prosecution, and the accused must be proven guilty, not merely possibly guilty.

Central to the Court's decision was the reliance on circumstantial evidence by the prosecution. While acknowledging the importance of such evidence in certain cases, the Court reiterated that the circumstances pointing to guilt must be firmly established and must exclude any reasonable alternative hypotheses. Any gaps or inconsistencies in the prosecution's case can cast doubt on the veracity of the charges.

In the case at hand, the Court meticulously examined the evidence presented by the prosecution, including the recovery of incriminating items allegedly linked to the crime. However, it found significant shortcomings in the prosecution's narrative, particularly regarding the admissibility and relevance of certain pieces of evidence.

For instance, the Court scrutinized the circumstances surrounding the recovery of a dagger, blood-stained clothes, and a rickshaw, noting discrepancies and lack of conclusive proof tying them to the accused. Additionally, the Court highlighted deficiencies in the forensic reports, further undermining the prosecution's case.

Crucially, the Court emphasized that the failure of the accused to provide a satisfactory explanation under Section 313 of the Code of Criminal Procedure cannot serve as a basis for conviction. While false or non-explanation may raise suspicion, it cannot substitute for concrete evidence establishing guilt beyond a reasonable doubt.

Case: Raja Naykar vs. State of Chhattisgarh,

CRIMINAL APPEAL NO. 902 OF 2023.

Click to read/download judgment.