RAMU APPA MAHAPATAR   [APPELLANT(S)]  Vs.  THE STATE OF MAHARASHTRA  [RESPONDENT(S)]

CRIMINAL APPEAL NO. 608 OF 2013

(2JB, ABHAY S. OKA and UJJAL BHUYAN JJ., delivered by UJJAL BHUYAN, J.)

The Supreme Court, while acquitting a murder accused, emphasized that extrajudicial confession is merely one form of circumstantial evidence. It reiterated that in cases based solely on circumstantial evidence, a conviction is valid only if all circumstances collectively establish the accused’s guilt beyond reasonable doubt. The Court stressed that these circumstances must be closely connected to the alleged crime, forming a complete and unbroken chain that rules out any possibility of innocence.

The case involved an appellant convicted of murdering his live-in partner. According to the prosecution, the appellant assaulted the victim following a quarrel, leading to her death. He later informed his landlord and the victim’s relatives about the incident. The Trial Court found him guilty based on circumstantial evidence, including his extrajudicial confession. The High Court upheld this conviction, prompting the appellant to challenge it before the Supreme Court.

The Supreme Court highlighted the necessity of careful scrutiny when dealing with circumstantial evidence. If the available evidence permits two reasonable interpretations, the one favoring the accused must be accepted. Referring to State of Rajasthan vs. Raja Ram (2003) 8 SCC 180, the Court emphasized that an extrajudicial confession must be voluntary and made in a fit state of mind. Additionally, citing Sahadevan vs. State of Tamil Nadu (2012) 6 SCC 403, it reiterated that such confessions are inherently weak and require corroboration by other evidence.

Upon reviewing the case, the Supreme Court found significant inconsistencies in the prosecution’s claims. The victim’s brother testified that the accused appeared confused when he allegedly confessed. The Court noted that this state of mind cast doubt on the reliability of the confession. Furthermore, crucial evidence, such as one of the murder weapons and any blood-stained clothing of the accused, was missing. The Court also questioned the accused’s behavior following the incident. Instead of confessing to the police, he first informed his landlord and then the victim’s brother. The latter’s reaction was also deemed unusual, as he accompanied the accused back to the crime scene instead of confronting him or immediately reporting the matter to the authorities.

Material omissions were identified in the statements of key witnesses, particularly discrepancies between their testimonies before the police and those given in court. The Supreme Court found that the extrajudicial confession lacked credibility, and the inconsistencies in the witnesses’ statements further weakened the prosecution’s case. Ultimately, the Court ruled that suspicion alone could not replace concrete evidence. The lack of corroboration and the questionable credibility of the evidence led the Court to conclude that the accused was entitled to the benefit of the doubt. Consequently, the previous judgments were set aside, and the accused was acquitted. The Court also ordered his immediate release, underscoring the principle that convictions must be based on solid and reliable evidence rather than mere conjecture.