In a groundbreaking decision, the Supreme Court of India has emphasized the crucial importance of a complete chain of evidence in cases relying on circumstantial evidence. Justices Vikram Nath and Ahsanuddin Amanullah, while hearing the case of Laxman Prasad @ Laxman v. State of Madhya Pradesh, held that if any link in the chain is missing or unproven, the conviction of the accused should be overturned.
The division bench highlighted that in cases where circumstantial evidence is the primary basis for the prosecution, it is imperative that the entire chain be established beyond doubt. Not only must the evidence point clearly towards the guilt of the accused, but it must also rule out any alternative theories of the crime.
The landmark judgment, which draws from previous rulings such as Sharad Birdichand Sharda v. State of Maharashtra (1984) and Sailendra Rajdev Pasvan v. State of Gujarat (2020), serves as a powerful reminder of the legal principle that no loose ends can be left when establishing guilt based on circumstantial evidence.
This development comes as a result of an appeal challenging a 2010 decision of the Madhya Pradesh High Court, which had upheld the conviction of the appellant under Section 302 of the Indian Penal Code, dealing with murder charges.
The police had relied on various strands of circumstantial evidence, including motive, the accused's last sighting, and the recovery of an assault weapon from the appellant. While the High Court found two of these links to be proven, it deemed the recovery of the weapon as unproven or invalid.
The Supreme Court, however, deemed the High Court's approach flawed and held that the conviction should have been overturned if any link in the chain was not established. Based on this reasoning and the settled legal position, the apex court set aside the appellant's conviction, leading to his acquittal.
This landmark decision by the Supreme Court reaffirms the importance of a complete and unbroken chain of circumstantial evidence. It serves as a resounding victory for justice, upholding the fundamental principle of "innocent until proven guilty" and emphasizing the need for meticulous investigation and presentation of evidence in criminal cases.
Case Title: Laxman Prasad @ Laxman v. State of Madhya Pradesh
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