❓ QUESTION
If someone is accused of a crime, but no witness can clearly identify them in court, and the recovered weapons are not scientifically linked to the crime, can they be convicted based on circumstantial evidence?
✅ ANSWER
No, a conviction cannot stand. The Supreme Court has firmly established that the identity of the accused as the actual perpetrator must be proven beyond a reasonable doubt. If the evidence fails to conclusively connect the accused to the crime, they must be given the benefit of the doubt.
In this case, the Court acquitted the accused because:
- The sole eyewitness who saw the attack could not name or identify the assailants.
- The other witnesses who claimed to identify the accused were found to be unreliable "chance witnesses" whose presence at the scene was doubtful.
- The recovered weapons were not forensically tested to prove they were used in the crime.
🧩 UNDERSTANDING THE LEGAL PRINCIPLES
⚖️ What the Supreme Court Has Clarified
1️⃣ The Identity of the Accused Must Be Proven, Not Presumed
The Court emphasized that establishing the identity of the accused as the person who committed the crime is the foundation of a criminal case.
- The Legal Principle: The prosecution must lead cogent (convincing and compelling) evidence to prove that the specific individuals on trial are the ones who committed the offence. Motive alone is not enough.
- In This Case: While the appellants had a prior quarrel with the victim's family, providing a possible motive, the Court stated this "by itself would not be sufficient to rope in the appellants unless their involvement in the offence is established by cogent evidence." The core issue was whether they were the actual assailants.
2️⃣ An Eyewitness Who Cannot Identify the Accused is of No Value
The Court drew a critical distinction between witnessing an event and identifying the perpetrators.
- The Legal Principle: A witness may truthfully see a crime occur but be unable to identify the criminals. If a witness does not know the accused by name and no identification parade is held, their testimony cannot legally connect the accused to the crime.
- In This Case: The key eyewitness, Amarjeet Kaur (PW-7), saw the murder happen in her own house. However, she clearly stated she "did not know the name of the accused persons." The police never held an identification parade for her to point out the attackers from a lineup. Therefore, her otherwise credible testimony could not prove that the appellants were the culprits.
3️⃣ The Testimony of a "Chance Witness" is Viewed with Great Caution
The Court reinforced a well-established legal principle regarding the reliability of witnesses who have no compelling reason to be at the scene of the crime.
- The Legal Principle: A "chance witness" is one whose presence at the place of incident appears to be accidental or coincidental. Courts must scrutinize their evidence closely and they must adequately explain their presence. If their presence is doubtful, their testimony is discarded.
- In This Case: The victim's father (PW-1) and another witness (PW-2) claimed to have seen the accused chasing the victim. The Court found their presence to be unnatural and doubtful. PW-1 took a route that was not on his way home, and PW-2 was simply going to buy soap. The Court held they were "chance witnesses" and their evidence could not be relied upon to identify the assailants.
4️⃣ Recovery of Weapons is Meaningless Without Forensic Corroboration
The Court explained the limited value of recovering weapons based on an accused's statement.
- The Legal Principle: Under Sections 25, 26, and 27 of the Indian Evidence Act, a confession made to the police is not admissible. Only the part of a statement that leads directly to the discovery of a fact (like a weapon) is admissible.
- The Critical Distinction: The police can prove that "the accused said, 'I hid the sword in the field,' and we found it there." They cannot prove that the accused said, "I hid the sword which I used to kill the victim." The latter part is an inadmissible confession.
- In This Case: The weapons were recovered but never sent for forensic analysis to match the blood on them with the deceased. Without this scientific link, the recovery only proves that the accused knew where the weapons were hidden, not that they were used in the murder.