A) ABSTRACT / HEADNOTE

This analysis examines Hansraj v. State of Chhattisgarh, Criminal Appeal No. 1387 of 2012, decided by a two-judge Bench of the Supreme Court on 10 February 2025, which reversed convictions under Section 302, Indian Penal Code and acquitted the appellant on the ground that the circumstantial case against him was not proved beyond reasonable doubt. The prosecution relied solely on circumstantial evidence: alleged motive (dispute over wages), last-seen inference, recovery of a farsi said to be the weapon, and blood-stained clothes.

The judgment applies the fivefold test in Sharad Birdhichand Sarda v. State of Maharashtra the so-called panchsheel for circumstantial proof and scrutinises each link: the uncorroborated testimony that the appellant returned because his cycle punctured; lack of independent proof that the cycle tyre was punctured; delayed recovery of the farsi on the appellant’s pointing out without forensic linkage of blood stains to the deceased; inconsistent witness statements about seeing the appellant flee; and failure to establish identity of the fleeing person.

The Court held the motive trivial and not established; found the chain of circumstances riddled with doubts; emphasised that circumstantial evidence must exclude every reasonable hypothesis of innocence; and concluded that benefit of doubt must go to the accused. The conviction and sentence imposed by trial and High Court were set aside and the appellant acquitted.

Keywords: Section 302 IPC; circumstantial evidence; last seen theory; chain of evidence; recovery of weapon; benefit of doubt.

B) CASE DETAILS

i) Judgment Cause Title: Hansraj v. State of Chhattisgarh.
ii) Case Number: Criminal Appeal No. 1387 of 2012.
iii) Judgment Date: 10 February 2025.
iv) Court: Supreme Court of India.
v) Quorum: Two Judges — Pankaj Mithal and Ahsanuddin Amanullah, JJ.
vi) Author: Pankaj Mithal, J.
vii) Citation: [2025] 2 S.C.R. 612 : 2025 INSC 178.
viii) Legal Provisions Involved: Section 302, Indian Penal Code, 1860.
ix) Judgments overruled by the Case (if any): None indicated.
x) Related Law Subjects: Criminal Law; Evidence Law (Circumstantial Evidence); Procedural aspects of proof and identification.

C) INTRODUCTION AND BACKGROUND OF JUDGEMENT

The Supreme Court considered an appeal against conviction for murder where the entire prosecution case rested on circumstantial materials and there were no direct eyewitnesses to the homicidal act. The deceased and the accused lived and worked together; a quarrel over wages was urged as motive. On the day of occurrence the accused is said to have left in the morning and returned claiming a punctured cycle; the deceased’s wife left to sell paddy leaving the deceased and accused at home; she returned to find the deceased dead with a severed neck and the accused absent or observed fleeing.

The prosecution relied on:

(a) the last seen proximity of the accused to the deceased;

(b) the recovery after 20–25 days of a farsi allegedly with blood stains upon the accused’s pointing out;

(c) production of the accused’s clothes said to bear blood stains; and

(d) the alleged motive of unpaid wages.

The High Court affirmed conviction; on appeal the Supreme Court re-examined whether the circumstantial proof satisfied the established tests, particularly the five-part test in Sharad Birdhichand Sarda, and whether the possibility of innocence had been excluded so as to permit conviction beyond reasonable doubt. The Court conducted a fact-sensitive review of identity, motive, recovery, and forensic linkage and concluded the chain of circumstances was incomplete and left room for a reasonable hypothesis of innocence.

D) FACTS OF THE CASE

The deceased Ramlal resided at Ghotha Sakulpara, District Kanker, Chhattisgarh. The appellant Hansraj had lived with and assisted him for over two months. On 28 March 2002 the appellant left the house at about 7:00 a.m. on his cycle for his native place, carrying a bag. He allegedly returned at about 9:00 a.m. stating his cycle tyre was punctured and sought money to repair it; the deceased’s wife Budhiyarin Bai (PW-5) asserted she had no cash and offered paddy to be sold instead. She then left to sell the paddy, leaving the deceased and appellant behind.

On her return at approximately 9:30 a.m. she found her husband prostrate, bleeding with a severed neck, and raised an alarm. She either saw the appellant fleeing or later reported him missing and neighbours came upon the scene. The village resident Jogi Ram (PW-1) lodged the FIR at 11:15 a.m. the same day. The prosecution alleged preceding discord over wages as motive; the accused was said to be last seen with the deceased and to have fled. Police recovered the appellant’s cycle and, on the appellant’s pointing out some 20–25 days later, a farsi (Ex. P/6) said to have blood stains; clothes purportedly worn by the appellant were produced by a hostile witness and also alleged to bear blood.

No forensic tests linking blood traces to the deceased were put on record. Witness testimony contained material inconsistencies as to whether and who saw the appellant running, and the identity of the fleeing person was not conclusively established.

E) LEGAL ISSUES RAISED

i. Whether the circumstantial evidence adduced by the prosecution satisfied the five-fold test in Sharad Birdhichand Sarda so as to exclude every reasonable hypothesis of innocence?
ii. Whether the alleged motive of non-payment of wages was sufficiently established and of such gravity as to support an inference of murder?
iii. Whether the last-seen evidence and witness testimony identified the appellant as the assailant beyond reasonable doubt?
iv. Whether the recovery of the farsi and blood-stained clothes, without forensic linkage, constituted reliable incriminating evidence?
v. Whether the delay and circumstances of recovery undermined the prosecution’s case and entitled the accused to benefit of doubt?

F) PETITIONER / APPELLANT’S ARGUMENTS

The counsel for the appellant submitted that the prosecution case was wholly circumstantial and riddled with contradictions. The asserted motive was trivial and unproved, the appellant’s return on account of a punctured cycle was not corroborated by independent evidence, and witnesses gave inconsistent accounts about seeing the accused fleeing. The recovery of the farsi was remote in time, its provenance doubtful (one witness said it originally lay in the open), and no forensic report linked blood on the weapon or clothing to the deceased. The appellant’s identity as the fleeing person was not established beyond a reasonable doubt and therefore conviction could not stand.

G) RESPONDENT’S ARGUMENTS

The counsel for the State maintained that the appellant was last seen in the company of the deceased and fled upon commission of the crime; recovery of the farsi at the accused’s instance and presence of blood stains on it and on clothes made a strong circumstantial case. The injuries were consistent with use of a farsi and the cumulative circumstances motive, last seen, recovery and blood stains pointed irresistibly to the appellant’s guilt.

H) JUDGEMENT

The Bench undertook a meticulous application of the panchsheel in Sharad Birdhichand Sarda and held that the prosecution failed to establish a complete chain of events to exclude every reasonable hypothesis of innocence. The Court found the alleged motive discord over non-payment/untimely payment of wages neither proved by material evidence nor of such gravity likely to prompt a brutal killing; motive thus remained speculative. The last-seen narrative was weak: all witnesses agreed the appellant had left in the morning and per PW-5 returned claiming a punctured tyre, but there was no independent corroboration (no inspection of the cycle tyres was carried out by police).

The Court observed it was unlikely that a person who had left in disgust for his native place would promptly return. The delayed recovery (20–25 days) of the farsi (Ex. P/6) at the appellant’s pointing out was suspect; a prosecution witness in cross-examination said a farsi was seen lying in the open at the place of occurrence, contradicting the claim of recovery from a field of another person. Crucially, no forensic report was produced to match blood stains on the weapon or clothes to the deceased; the medical opinion that the injuries could have been caused by a similar instrument could not substitute for proof that the recovered farsi was in fact the weapon used.

Witness evidence about seeing the appellant fleeing was inconsistent: PW-5’s statements varied between not seeing the appellant at the place and later seeing him running with a farsi; PW-1 admitted seeing an unnamed man running a furlong away and later conveyed only that the appellant had disappeared. Given these contradictions the identity of the fleeing person was not established conclusively. Acceptance of the prosecution’s theory would require inferences impermissibly drawn from possibilities rather than certainties.

Applying the tests in Sharad Sarda, the Court concluded the facts did not create a chain of evidence excluding every reasonable hypothesis of innocence. Consequently, the benefit of doubt went to the appellant and the convictions were set aside; the appellant’s long incarceration (over ten years) was noted and bail/surety orders addressed.

a. RATIO DECIDENDI

The ratio rests on the proposition that in purely circumstantial cases the prosecution must establish a chain of circumstances which is complete and incompatible with any reasonable hypothesis of innocence. Where material links are unproved, inconsistencies exist about identity and recovery, and forensic linkage is absent despite available opportunities, the doubt is real and substantial and must result in acquittal. The triviality and non-establishment of motive, absence of independent corroboration for last-seen evidence, doubtful provenance and delayed recovery of weapon, and lack of blood-matching collectively precluded conviction beyond reasonable doubt; hence acquittal followed.

b. OBITER DICTA 

While not central to ratio, the Court emphasised that commonly used farm implements (such as a farsi) cannot be treated as uniquely incriminating without concrete proof; medical opinion alone on weapon-type is insufficient; and courts must carefully scrutinise inconsistencies in witness testimony concerning identity of a fleeing figure rather than accept speculative inferences.

c. GUIDELINES 

i. In circumstantial prosecutions, courts must apply the five tests in Sharad Birdhichand Sarda strictly.
ii. Recovery of a weapon must be promptly established and forensic linkage to the victim is critical where feasible.
iii. Last-seen evidence requires independent corroboration; mere presence near time of death is not conclusive without identity and opportunity.
iv. Contradictions in core testimony about flight, identity, or recovery diminish the probative value of the prosecution’s case.
v. Trivial or unproven motive should not be read into grave inferences of intention to kill.

I) CONCLUSION & COMMENTS

The Court’s decision reinforces established criminal-evidence principles: circumstantial chains must be unbroken and leave no reasonable hypothesis of innocence. This judgment underscores the practical significance of timely, forensic investigation and the need to test witness consistency on identity and flight. The ruling also cautions prosecutors against reliance on commonplace instruments as presumed unique weapons without scientifc corroboration and highlights that motive must be demonstrated by credible material to bear on mens rea. For trial courts, the case reiterates that even cumulative but individually weak circumstances cannot substitute for missing links; justice requires that reasonable doubt operate as a shield against wrongful conviction. The acquittal thus aligns with the safeguarding function of beyond reasonable doubt in criminal jurisprudence.

J) REFERENCES

a. Important Cases Referred

i. Sharad Birdhichand Sarda v. State of Maharashtra, (1984) 4 SCC 116.
ii. Hansraj v. State of Chhattisgarh, Criminal Appeal No. 1387 of 2012, Judgment dated 10 February 2025 (Supreme Court).

b. Important Statutes Referred

i. Indian Penal Code, 1860 — Section 302 (Punishment for murder).