Raghunatha vs. State of Karnataka [Supreme Court, March 21, 2024]
Background
The case arose from the conviction of Raghunatha (Accused No. 1) and Manjunatha (Accused No. 2) for the murder of an individual in Kolar district, Karnataka, in July 2014. The trial court convicted both under Sections 120-B and 302 read with Section 34 of the Indian Penal Code (IPC) and sentenced them to life imprisonment. On appeal, the Karnataka High Court modified the conviction to Section 304 Part-I of IPC (culpable homicide not amounting to murder) and reduced the sentence to 10 years’ imprisonment, also imposing a fine, part of which was directed to be paid to the deceased’s widow.
Prosecution Case and Evidence
The prosecution’s case rested entirely on circumstantial evidence. Key elements included:
The deceased’s unattended two-wheeler was found by a witness (PW-6), who informed the deceased’s son and brother. They subsequently discovered the deceased’s body nearby.
The prosecution claimed that the chain of circumstances established the guilt of the accused beyond reasonable doubt.
Defence Arguments
Counsel for the appellants argued that:
The conviction was based solely on circumstantial evidence, with no direct evidence linking the accused to the crime.
The prosecution failed to establish a complete chain of circumstances that would rule out any hypothesis other than the guilt of the accused.
The legal standard, as laid down in Sharad Birdhichand Sarda v. State of Maharashtra, requires that the circumstances must be fully established and must point only to the guilt of the accused, not merely raise suspicion.
Supreme Court’s Analysis
The Supreme Court, led by Justice B.R. Gavai, reiterated the principles governing conviction based on circumstantial evidence:
Suspicion, however strong, cannot substitute proof beyond reasonable doubt.
The chain of circumstances must be so complete that it leaves no reasonable ground for a conclusion consistent with the innocence of the accused.
Upon review, the Court found that the prosecution had not established the incriminating circumstances with the required degree of certainty. The evidence did not form a complete chain pointing only to the guilt of the appellants. The “last seen” theory and other circumstantial evidence were deemed insufficient to meet the legal threshold for conviction.
Judgment
The Supreme Court allowed the appeal, set aside the conviction and sentence imposed by the High Court and the trial court, and acquitted the appellants of all charges. The Court emphasized that the presumption of innocence remains until guilt is proved beyond reasonable doubt and that the benefit of doubt must go to the accused.
Citation:
Raghunatha & Anr. v. State of Karnataka, Supreme Court of India, Neutral Citation: 2024 INSC 238, Judgment dated March 21, 2024.
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