The People vs. State of Madhya Pradesh: Landmark Judgement on Circumstantial Evidence

In a significant ruling by the Supreme Court of India, a landmark judgement has been delivered in the case of The People vs. State of Madhya Pradesh. The decision centers around the use of circumstantial evidence in criminal cases, setting a precedent for future legal proceedings. This judgement is expected to have a lasting impact on the legal landscape of the country.

Facts

On 13.11.2011, at 9.30 p.m., Rachna Bai heard a gunshot while she and Narayan Singh were sleeping at their house in Village Binjana, District Dewas, Madhya Pradesh.
A pistol (Exhibit P-6) was recovered from the appellant, Santosh @ Rajesh @ Gopal.
Chargesheet was filed against five individuals, including family members of the victim – Laadkunwar Bai, Jitendra Singh, and Meharban Singh, as well as Santosh @ Rajesh @ Gopal and Nirbhay Singh @ Rajesh Mama.
Evidence includes the recovery of a pistol (Exhibit P-6) and a ballistic report (Exhibit P-57) confirming the bullet from the victim was fired from the country-made pistol.
Narayan Singh was called outside after someone called his name, following which he was shot in the chest.
Santosh @ Rajesh @ Gopal’s conviction was upheld in the case, while Nirbhay Singh @ Rajesh Mama’s appeal was dismissed post his demise.
Laadkunwar Bai and Meharban Singh were acquitted by the trial court on 30.11.2017.
Nirbhay Singh @ Rajesh Mama, Jitendra Singh, and the appellant filed appeals before the High Court of Madhya Pradesh at Indore.
Jitendra Singh has been acquitted by the High Court on 18.10.2022.
The appeals were in relation to the trial court’s acquittal of Laadkunwar Bai and Meharban Singh.

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Analysis

The ballistic report connects the pistol recovered from the appellant with the bullet recovered from the victim, which is an inculpatory fact.
The discovery and recovery of the pistol are attributed to a disclosure statement provided by the deceased co-accused, Nirbhay Singh, governed by Sections 8 and 27 of the Indian Evidence Act, 1872.
Conditions required to be satisfied under Section 27 from the case law Perumal Raja v. State, Represented By Inspector of Police, which refers to Mohmed Inayatullah v. State of Maharashtra.
No eyewitnesses to the crime implicating the appellant.
Facts proved by the prosecution give rise to two alternative hypotheses which need to be analyzed by the court.
Absence of any corroborative evidence directly linking the appellant to the crime introduces a significant gap in the chain of circumstances.
The case against the appellant rests entirely on circumstantial evidence.
The prosecution may take benefit of Section 8 of the Indian Evidence Act, 1872, only in relation to the discovery of a physical object.
In the case of State of Maharashtra v. Suresh, three hypotheses emerge when incriminating material is discovered based on a disclosure statement.
The prosecution’s case in this instance is that the location of the pistol was disclosed by the co-accused, Nirbhay Singh.
To establish the appellant’s participation in the murder, further material and evidence linking the appellant to the actual crime are required.
The prosecution failed to prove the appellant’s guilt of murder on 13.11.2011.
A complete chain of evidence, excluding all hypotheses but the one proposed to be proved, must be present in cases based on circumstantial evidence.
The ‘golden rules’ outlined in Sharad Birdhichand Sharda v. State of Maharashtra must be satisfied for circumstantial evidence to conclusively establish the guilt of the accused.
Evidence obtained from a person accused of an offense can be admissible if it leads to the discovery of a fact related to the offense.
The information must distinctly lead to the discovery of a fact in consequence of the information received.
The distinctly relevant part of the statement can be used as evidence against the accused.
This rule applies when the fact discovered directly relates to the information provided by the accused.
Failure to establish a hypothesis of guilt conclusively excluding all other reasonable possibilities
Lack of conclusive evidence pointing solely to one specific conclusion
Inadequacy in proving guilt without a doubt beyond reasonable possibilities