The Supreme Court, in a significant ruling, acquitted the co-accused in a murder case arising from Karnataka, holding that conviction based solely on circumstantial evidence—particularly the “last seen together” theory—cannot be sustained unless supported by a complete and unbroken chain of evidence.
The bench of Justice J.B. Pardiwala and Justice K. V. Viswanathan has observed that the alleged motive was attributable only to the main accused, who had financial disputes with the deceased. There was no clear evidence showing that the co-accused shared any motive or common intention to commit the crime. Their alleged presence with the main accused, without more, could not justify conviction for a serious offence like murder.
The case involved the alleged abduction and murder of a woman who went missing in March 2013. Her charred skeletal remains were later discovered in a forest area. Based on the investigation, four accused persons were charged under serious offences including murder, kidnapping, destruction of evidence, and common intention. The Trial Court convicted all accused and sentenced them to life imprisonment, which was subsequently upheld by the High Court.
The prosecution’s case was built entirely on circumstantial evidence. It relied on factors such as the deceased being last seen with the accused, recovery of certain articles including a rope and petrol container, forensic identification of the body, and an alleged financial dispute between the deceased and the main accused. According to the prosecution, the motive stemmed from a loan of around ₹20 lakh and gold ornaments that the main accused had failed to return.
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Upon examining the record, the Supreme Court noted that while the evidence may raise suspicion, it fell short of establishing guilt beyond reasonable doubt against the co-accused. The Court emphasised that in cases based on circumstantial evidence, every link in the chain must be firmly established and must exclude all other possible hypotheses except that of guilt.
The Court was particularly critical of the reliance placed on the “last seen together” theory. It held that this principle, by itself, is insufficient to convict an accused unless there is strong corroborative evidence showing a close proximity between the last seen instance and the death, along with other incriminating circumstances. In the present case, the Court found that such corroboration was lacking.
The Court also found deficiencies in the prosecution’s reliance on recovery and disclosure statements. It noted that recoveries were largely linked to the main accused, and the attempt to implicate the co-accused through joint disclosures was legally untenable. Additionally, confessional statements recorded by the police were inadmissible under the Evidence Act and could not be relied upon.
Reiterating settled legal principles, the Supreme Court held that suspicion, however strong, cannot take the place of proof. The chain of circumstantial evidence must be complete and incapable of explanation on any hypothesis other than guilt. In the absence of such a complete chain, the accused is entitled to the benefit of doubt.
Accordingly, the Court allowed the appeals and acquitted the co-accused, setting aside their conviction. The ruling underscores the judiciary’s consistent approach in safeguarding against wrongful convictions in cases based purely on circumstantial evidence.
Case Details
Case Title: Anand Jakkappa Pujari @Gaddadar Versus The State Of Karnataka
Citation: JURISHOUR-969-SC-2026
Case No.: Criminal Appeal No. 1864 Of 2024
Date: 27/04/2026
