A) ABSTRACT / HEADNOTE

This case involved an appeal against the conviction of the accused under Sections 302, 34, 120B, and 201 of the Indian Penal Code, 1860 (IPC), based on circumstantial evidence. The issue revolved around the admissibility and reliability of evidence obtained under Section 27 of the Indian Evidence Act, 1872. The prosecution alleged that the accused conspired and committed murder, later disposing of the victim’s body in a pond, which was allegedly recovered based on their disclosure. However, the Supreme Court highlighted procedural lapses, contradictions in witness testimonies, and the prosecution’s failure to establish an unbroken chain of circumstantial evidence. The court quashed the convictions, emphasizing the standards for reliance on circumstantial evidence and disclosure statements.

Keywords: Circumstantial evidence, Chain of evidence, Section 27 of Evidence Act, Disclosure statement, Beyond reasonable doubt.

B) CASE DETAILS

• i) Judgement Cause Title: Ravishankar Tandon v. State of Chhattisgarh
• ii) Case Number: Criminal Appeal No. 3869 of 2023
• iii) Judgement Date: 10 April 2024
• iv) Court: Supreme Court of India
• v) Quorum: B.R. Gavai and Sandeep Mehta, JJ.
• vi) Author: B.R. Gavai, J.
• vii) Citation: [2024] 4 S.C.R. 558; 2024 INSC 299
• viii) Legal Provisions Involved:
  • Section 302, 34, 120B, 201 of IPC
  • Section 27 of the Indian Evidence Act, 1872
• ix) Judgments Overruled: None
• x) Case Related to Law Subjects: Criminal Law, Evidence Law

C) INTRODUCTION AND BACKGROUND OF JUDGEMENT

This case emerged from the alleged murder of Dharmendra Satnami, whose body was found in a pond following a series of arrests and interrogations. The prosecution charged the appellants with conspiracy and murder based on circumstantial evidence, which included confessional statements under Section 27 of the Evidence Act. The trial court and High Court affirmed the convictions, relying heavily on these disclosures. However, the appellants challenged the authenticity of these statements and the adequacy of the evidence.

D) FACTS OF THE CASE

1. On 2 December 2011, Dharmendra Satnami was reported missing by his father at Police Station Kunda.
2. On 3 December 2011, based on the appellants’ disclosure under Section 27, the police recovered the victim’s body from a pond.
3. Post-mortem confirmed asphyxia due to strangulation as the cause of death, classifying it as homicide.
4. The prosecution alleged that the accused, in a conspiracy orchestrated by Dinesh Chandrakar, murdered the victim for a monetary reward of ₹90,000.
5. The trial court convicted the accused under Sections 302, 34, 120B, and 201 IPC, and the High Court upheld the decision on appeal.
6. The Supreme Court reviewed the appeals based on alleged gaps in evidence and the procedural validity of Section 27 disclosures.

E) LEGAL ISSUES RAISED

1. Was the prosecution able to prove the chain of circumstantial evidence leading to the guilt of the accused?
2. Did the disclosure statements under Section 27 of the Evidence Act satisfy the legal requirements of admissibility?
3. Could the recovery of the victim’s body be solely attributed to the information provided by the accused?

F) PETITIONER/APPELLANT’S ARGUMENTS

1. The case rested entirely on circumstantial evidence, which failed to establish guilt beyond reasonable doubt.
2. The prosecution’s chain of evidence was incomplete, leaving room for alternative hypotheses.
3. The disclosure statements recorded under Section 27 were unreliable due to procedural irregularities and contradictions in witness testimonies.
4. Witnesses, including PW-5 and PW-18, admitted to signing documents without verifying their contents, casting doubt on their credibility.
5. The police already knew about the victim’s death before the accused’s disclosures, undermining the claim of discovery under Section 27.

G) RESPONDENT’S ARGUMENTS

1. The prosecution established a clear chain of circumstances linking the accused to the crime.
2. The accused’s disclosures directly led to the recovery of the victim’s body, satisfying the requirements of Section 27.
3. The concurrent findings of the trial court and High Court warranted no interference.
4. Witness testimonies corroborated the prosecution’s narrative despite minor inconsistencies.

H) JUDGEMENT

a. Ratio Decidendi

1. Standards for Circumstantial Evidence:

   • The court reiterated the principles laid down in Sharad Birdhichand Sarda v. State of Maharashtra ([1984] 4 SCC 116), emphasizing that circumstantial evidence must conclusively point to guilt, excluding all other hypotheses.
   • The chain of evidence in this case was incomplete and left reasonable doubt about the accused’s guilt.

2. Section 27 Disclosures:

   • The court held that the prosecution failed to prove that the body’s recovery stemmed solely from the accused’s disclosures.
   • Witnesses admitted that the police and villagers knew about the body’s location beforehand, nullifying the claim of discovery.

3. Procedural Irregularities:

   • The court found significant lapses, including unsigned and contradictory witness statements, raising doubts about the authenticity of evidence.

b. Obiter Dicta

• The judgment emphasized the importance of strict adherence to procedural requirements under Section 27 to avoid misuse and ensure justice.

c. Guidelines

1. Circumstantial evidence must form a complete chain with no gaps or alternative explanations.
2. Statements under Section 27 must lead to a discovery that was unknown before the disclosure.
3. Courts must scrutinize witness credibility and procedural adherence in circumstantial evidence cases.

I) CONCLUSION AND COMMENTS

The Supreme Court’s judgment reflects a robust application of evidentiary principles, ensuring that justice is not compromised by procedural lapses. The case underscores the high standards required for convictions based on circumstantial evidence and the necessity of reliable disclosures under Section 27 of the Evidence Act.

J) REFERENCES

1. Sharad Birdhichand Sarda v. State of Maharashtra ([1984] 4 SCC 116)
2. State (NCT of Delhi) v. Navjot Sandhu alias Afsan Guru ([2005] 11 SCC 600)
3. Asar Mohammad v. State of Uttar Pradesh ([2019] 12 SCC 253)
4. Boby v. State of Kerala ([2023] SCC OnLine SC 50)
5. Indian Evidence Act, 1872
6. Indian Penal Code, 1860