Mere Recovery of Weapon Insufficient if No Link to Crime Established: SC

Gautam Satnami Vs State of Chhattisgarh (Supreme Court of India)

In Gautam Satnami Vs State of Chhattisgarh, the Supreme Court of India examined an appeal against concurrent findings of conviction under Section 302 IPC by the Trial Court and the High Court. The case was based entirely on circumstantial evidence, as there was no direct evidence linking the appellant to the murder of the deceased.

The prosecution relied on several circumstances, including alleged prior enmity, a “last seen” theory, recovery of a blood-stained axe and clothes pursuant to disclosure statements under Section 27 of the Evidence Act, forensic findings, and recovery of the appellant’s driving licence from the crime scene. The appellant challenged the reliability of these circumstances, pointing to contradictions, lack of corroboration, and improper appreciation of evidence.

The Supreme Court reiterated the settled principles governing circumstantial evidence, emphasizing that all links in the chain must be fully established and must conclusively point only to the guilt of the accused. It found that the “last seen” evidence was unreliable, as identification at night was doubtful due to lack of lighting, and the witness testimony did not establish that the appellant committed the offence. The Court also noted that the witness may have been an “interested” witness due to prior hostility.