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The Court asserted that continued incarceration of the applicants had to be balanced against their fundamental right to life and personal liberty guaranteed under Article 21 of the Constitution.
The Court noted that the presence of the appellant at the time of occurrence at the scene of crime has not been proved beyond reasonable doubt and no active role has been assigned to him and the chain of the evidence is not consistent only with the hypothesis of the guilt of the accused.
Supreme Court held that while frequent phone calls alone cannot establish criminal conspiracy, a complete and unbroken chain of circumstantial evidence, including recoveries admissible under Section 27, Evidence Act, and the accused’s conduct was sufficient to uphold the husband’s conviction for the premeditated murder of his wife.
“Having found that present applicant was not present at the scene of offence and was also not visible at the District Court, Surat as alleged by the complainant from the CCTV footage, the said aspect would itself demolish the very basis of the FIR against the present applicant.”
“Even a strong suspicion was not enough to convict a person and that the prosecution had to necessarily prove each circumstance in the chain beyond reasonable doubt.”
“Just because the accused happened to be the wife of the deceased, it cannot be assumed that she would always be present with the deceased inside the house.”
“Criminal liability is founded on legally admissible material capable of giving rise to a sustainable inference, and not on conjecture, or investigative imagination.”
“The Railways Act is a beneficial legislation, and even in criminal matters, circumstantial evidence is taken into consideration for deciding whether the offence was committed or not.”
“When a person’s identification is at issue, the information that is most beneficial in determining his identity is considered a relevant fact. On their own, certain pieces of evidence may seem devoid of significance, but when considered in conjunction with other facts, they may become relevant.”
The accused is a prime suspect in a murder case, as he had previously harassed the deceased. However, the Court opined that he cannot be convicted based on the feelings of the deceased’s parents, when not a shred of evidence can be found which connects the accused with the crime.
“The petitioner is grievously bereft of the invaluable opportunity to fulfill her natural and fundamental role as a mother the nurturing, upbringing, and intimate bonding with her child.”
“Creating a false appearance of having solved a case by presenting that the accused had been brought to justice gave a misleading sense of resolution. This deceptive closure undermined public trust and falsely reassured society, while in reality, the true threat remained at large.”
The case involved commission of serious offences which led to the sentence of death penalty. However, the Supreme Court took strict note of the faulty investigation and faulty treatment of the DNA evidence that rendered the samples useless.
“Scope of interference in the acquittal order passed by the Trial Court is very limited, and if the impugned judgment of the Trial Court demonstrates a legally plausible view, mere possibility of a contrary view shall not justify the reversal of acquittal.”
“The subsequent acts of cleaning up the crime scene and making false enquiries amount to disappearance of evidence and raise grave suspicion against the convict. However, mere suspicion, no matter how grave, cannot take the place of proof in a criminal trial”.
Arbitration and Conciliation Act, 1996 — Ss. 7, 34 and 37 — Arbitration agreement — Bindingness of, on non-signatory — Group of Companies Doctrine
“The motive for the commission of the offence was absent and the same was very relevant as the case was based on circumstantial evidence.”
The Court found that circumstances in the instant case constituted more than a prima facie case to enable the prosecution to invoke Section 106 of the Evidence Act and shift the burden on the accused husband to explain what had happened on the day & date his wife died.
The Court found that circumstances in the case constitute more than a prima facie case to enable the prosecution to invoke Section 106 of the Evidence Act and shift the burden on the accused husband to explain what had happened on the day & date his wife died.
“When one of the three circumstances was disbelieved and discarded by the High Court, then the chain of circumstantial evidence could not have been held to be complete and proved and on that basis to hold the accused guilty of the offence.”