Judicial Updates-
SUPREME COURT - IN CASE OF CIRCUMSTANTIAL EVIDENCE, CHAIN OF CUSTODY HAS TO BE COMPLETE IN ALL RESPECT.
In the case of Laxman Prasad @Laxman v. State of Madhya Pradesh [Criminal Appeal No(s). 821/2012], the appeal was filed to challenge the accuracy of the decision and order rendered by the High Court of Madhya Pradesh, Gwalior bench. The High Court had upheld the decision of the trial court for the conviction and life sentence u/s 302 of the Indian Penal Code, 1860.
Aggrieved by the decision of the High Court, the Appellant filed the present appeal. The issue before the Supreme Court was with respect to law surrounding circumstantial evidence.
The prosecution had presented evidence to demonstrate the three links of the chain: (i) motive, (ii) last seen, and (iii) recovery of the weapon of assault. In its analysis of the evidence presented, the High Court concurred with the determination of the Appellant's motive and last seen. However, in paragraph 18 of its ruling, the High Court declared the recovery of the assault weapon and blood-stained clothing to be invalid and even went so far as to claim that it was no evidence that the Appellant had committed the crime. However, the conviction was upheld upon considering the full range of other conclusive evidence against the Appellant, including his last seen and motive.
The Supreme Court referred the case of Sharad Birdhichand Sarda v. State of Maharashtra [(1984) 4 SCC 116] and Sailendra Rajdev Pasvan v. State of Gujarat [AIR 2020 SC 180], and reaffirmed that in a case involving circumstantial evidence, "the chain has to be complete in all respects so as to indicate the guilt of the accused."
The Supreme Court noted that the High Court determined that one of the links was absent and unproven in accordance with established Legal principles, but failed to interfere with the conviction.
Thus, the Supreme Court allowed the appeal.
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