A) ABSTRACT / HEADNOTE

This case examines the acquittal of Karakkattu Muhammed Basheer (the appellant), charged under Sections 302 and 201 of the Indian Penal Code (IPC), for the alleged murder of Gouri. The prosecution’s case rested on circumstantial evidence, asserting that Basheer, in conspiracy with Accused No. 2, murdered Gouri due to her alleged interference in an illicit relationship between the two accused. However, the prosecution failed to conclusively establish the guilt of the appellant. The Supreme Court acquitted him, finding significant gaps in the chain of circumstantial evidence. The judgment reinforced principles of circumstantial evidence, including the necessity of proving an unbroken chain of events that lead to no hypothesis other than guilt.

Keywords: Circumstantial Evidence, Murder, Acquittal, Reasonable Doubt, Chain of Circumstances.

B) CASE DETAILS

i) Judgment Cause Title: Karakkattu Muhammed Basheer v. The State of Kerala
ii) Case Number: Criminal Appeal No. 291 of 2023
iii) Judgment Date: 05 November 2024
iv) Court: Supreme Court of India
v) Quorum: Justice Abhay S. Oka and Justice Augustine George Masih
vi) Author: Justice Augustine George Masih
vii) Citation: [2024] 11 S.C.R. 498 : 2024 INSC 838
viii) Legal Provisions Involved: Sections 302, 201 of the Indian Penal Code
ix) Judgments Overruled by the Case: None
x) Case is Related to: Criminal Law – Homicide, Evidence Law

C) INTRODUCTION AND BACKGROUND OF JUDGMENT

The judgment arose from an appeal against a Kerala High Court decision affirming the appellant’s conviction under Sections 302 and 201 IPC. The alleged motive was an illicit relationship between the accused, with the deceased purportedly interfering. The Sessions Court and the High Court upheld the conviction. However, the appellant challenged the verdict, asserting procedural lapses, unconvincing circumstantial evidence, and insufficient proof beyond reasonable doubt.

D) FACTS OF THE CASE

1. On 17 August 1989, Gouri’s body was found in a paddy field by a local (PW1).
2. The police registered a case of unnatural death and launched an investigation, leading to the arrest of the appellant (Accused No. 1) and another individual (Accused No. 2).
3. The prosecution alleged that Gouri, staying at Accused No. 2’s residence, was killed by the appellant using a coconut scraper. Her body was allegedly disposed of in the nearby field.
4. The motive cited was Gouri’s interference in the relationship between the accused.
5. The prosecution relied on circumstantial evidence, including witness statements, the alleged recovery of the murder weapon, and forensic evidence.

E) LEGAL ISSUES RAISED

i) Whether the circumstantial evidence presented established the guilt of the appellant beyond reasonable doubt.
ii) Whether the prosecution demonstrated a complete and unbroken chain of events linking the accused to the crime.

F) PETITIONER/APPELLANT’S ARGUMENTS

i) Incomplete Chain of Circumstances: Counsel argued that the evidence lacked continuity, failing to connect the appellant conclusively to the crime scene.
ii) Doubtful Witness Testimony: Key witnesses provided contradictory statements, undermining the prosecution’s narrative.
iii) Improper Recovery Process: The alleged recovery of incriminating items was contested as staged and unsupported by independent witnesses.
iv) Absence of Eyewitnesses: The case relied entirely on circumstantial evidence without direct corroboration.
v) Gaps in Motive and Timing: The alleged timeline of events and motive were speculative and unsupported.

G) RESPONDENT’S ARGUMENTS

i) Evidence of Presence: Witnesses saw the appellant near the victim’s location, allegedly placing him at the crime scene.
ii) Motive Established: The illicit relationship provided a strong basis for conflict and motive for the murder.
iii) Recovery of Incriminating Material: The discovery of blood-stained articles and the weapon at the appellant’s behest corroborated his involvement.
iv) Consistency Across Evidence: The chain of circumstantial evidence, though indirect, pointed conclusively to the appellant’s guilt.H) JUDGMENT

Ratio Decidendi:
The Court held that the prosecution failed to establish the guilt of the appellant beyond reasonable doubt. The chain of circumstances was neither complete nor consistent, leaving significant gaps.

Obiter Dicta:
The judgment emphasized caution in relying solely on circumstantial evidence, stressing that any doubt must benefit the accused.

Guidelines:

1. In cases based on circumstantial evidence, the prosecution must demonstrate an unbroken chain of events leading to guilt.
2. Suspicion, however strong, cannot substitute proof.
3. Recoveries and witness testimonies must withstand rigorous scrutiny.

I) CONCLUSION & COMMENTS

The Supreme Court rightly acquitted the appellant due to inadequate evidence. The judgment serves as a reminder of the high evidentiary standards required in criminal law, especially in cases relying entirely on circumstantial evidence. The principles reaffirmed here will likely guide future adjudications.

J) REFERENCES

a) Important Cases Referred:
i. Ramreddy Rajesh Khanna Reddy and Another v. State of A.P. [2006] 3 SCR 348; (2006) 10 SCC 172.
ii. Anil Kumar Singh v. State of Bihar (2003) 9 SCC 67.
iii. Bodhraj v. State of J&K (2002) 8 SCC 45.

b) Important Statutes Referred:
i. Sections 302, 201, IPC
ii. Principles governing circumstantial evidence from prior Supreme Court decisions.