The Supreme Court has set aside the conviction of a constable accused of murdering his superior officer, holding that the prosecution failed to establish a complete and reliable chain of circumstantial evidence, and that key witness testimony suffered from serious inconsistencies.

The bench of Justices Dipankar Datta and Satish Chandra Sharma, critically examined the evidentiary record and found multiple deficiencies: The prosecution relied heavily on the testimony of a witness (PW-3), who initially claimed to have seen the accused with the weapon. However, during cross-examination, he admitted that due to darkness, he could not clearly see the person and identified the accused only by voice.

The bench held that such a contradiction significantly undermined the credibility of the witness.The case lacked any direct eyewitness. Other witnesses were either hearsay witnesses or turned hostile, weakening the prosecution’s case. Although ballistic evidence suggested that the bullets were fired from a particular rifle, the link connecting the accused to that weapon remained doubtful. 

The bench also questioned the plausibility of a rifle exchange between personnel going unnoticed for several days in a disciplined force. The duty register for the date of the incident was not produced, further breaking the chain of circumstances.

The case arose from the alleged killing of Sub-Inspector Sunil Soren in May 2014 at an Indian Reserve Battalion camp in Jharkhand. The accused, a constable, was convicted by the Trial Court under Section 302 of the IPC and Section 27 of the Arms Act, and sentenced to life imprisonment along with an additional seven-year term. The conviction was later affirmed by the High Court.

Challenging this, the accused approached the apex court.

At the heart of the case was whether the prosecution had proved guilt beyond reasonable doubt based solely on circumstantial evidence, especially when the primary witness’s identification of the accused was doubtful.

The Court reiterated the well-settled principle laid down in Sharad Birdhichand Sarda v. State of Maharashtra, emphasizing that every link in the chain of circumstantial evidence must be firmly established. The chain must point unerringly to the guilt of the accused. If two views are possible, the one favouring the accused must prevail.

Applying these principles, the Court held that the evidence on record did not exclude every reasonable hypothesis of innocence.

Concluding that the prosecution failed to meet the high standard of proof required in criminal law, the Supreme Court set aside the conviction and sentence, acquitted the appellant, and directed his immediate release after nearly 12 years in custody.

The Court also granted the appellant liberty to seek reinstatement in service, subject to fitness, or alternatively, claim appropriate financial compensation.

Case Details

Case Title: Jay Prakash Yadav Versus The State Of Jharkhand

Citation: JURISHOUR-621-HC-2026(Ker) 

Case No.: SLP (Crl.) No. 2536 of 2026

Date: 06/04/2026

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