New Delhi

The Supreme Court on Friday overturned the life sentence of an accused in a 21-year-old murder case, ruling that a conviction cannot be based solely on the “last seen together” theory without a complete chain of circumstantial evidence. A bench of Justices Sanjay Karol and Prashant Kumar Mishra set aside the Chhattisgarh High Court and trial court judgments, which had convicted the appellant under Sections 302 and 201 of the IPC, awarding life imprisonment for murder and five years for destroying evidence.

The prosecution claimed the appellant and others lured a tractor driver under the pretext of collecting cable wire. The driver was later found dead with burn injuries. While five co-accused were acquitted, the appellant was convicted mainly based on witness testimony regarding last-seen circumstances.

The Supreme Court emphasised that circumstantial evidence must form a complete and coherent chain, pointing solely to the accused’s guilt. “Circumstantial evidence can support conviction only when wholly inconsistent with innocence and consistent only with guilt,” the bench said, rejecting the sole reliance on last-seen testimony.

The court also criticised the High Court’s use of Section 106 of the Evidence Act, noting that failure to explain separation from the deceased does not relieve the prosecution of proving guilt beyond reasonable doubt. The absence of motive or corroborative evidence further strengthened the benefit-of-doubt ruling.

“In this case, the evidence may raise suspicion, but it is not conclusive enough to convict solely on last seen together,” the bench observed. The Supreme Court acquitted the appellant of all charges and discharged his bail bonds, as he was already out on bail.