Home > Recent Judgements > Supreme Court Acquits Accused in 30-Year-Old Murder Case: Key Verdict on Circumstantial Evidence in Arun Shankar v. State of Madhya Pradesh (April 10, 2025)
April 11, 2025
Supreme Court Acquits Accused in 30-Year-Old Murder Case: Key Verdict on Circumstantial Evidence in Arun Shankar v. State of Madhya Pradesh (April 10, 2025)
On April 10, 2025, the Supreme Court of India delivered a significant judgment in the case of Arun Shankar v. State of Madhya Pradesh, acquitting the appellant in a three-decade-old murder case. The Court found that the circumstantial evidence presented was insufficient to conclusively establish the appellant’s guilt, leading to the reversal of his conviction.
Case Background
In 1995, Arun Shankar was convicted of the murder of his relative, Sushildhar Dubey, based primarily on circumstantial evidence. The key elements of the prosecution’s case included the “last seen together” theory and the alleged recovery of the murder weapon a knife from the appellant’s possession.
Supreme Court’s Analysis
The Supreme Court emphasized the stringent standards required for convictions based solely on circumstantial evidence, referencing the principles established in Sharad Birdhichand Sarda v. State of Maharashtra (1984). The Court highlighted the necessity for:
- Established Circumstances: Each circumstance must be firmly proven.
- Consistency with Guilt: The facts should align exclusively with the accused’s guilt, leaving no room for alternative explanations.
- Conclusive Nature: The circumstances should be definitive and compelling.
- Exclusion of Other Hypotheses: All other possible explanations must be ruled out.
- Complete Chain of Evidence: The evidence should form an unbroken chain, pointing solely to the accused’s guilt.
Applying these criteria, the Court assessed the prosecution’s evidence:
- Last Seen Together: While the appellant and the victim were together before the latter’s death, there was no evidence of a dispute or motive for the appellant to harm the victim. Their shared habit of drinking together rendered this circumstance weak and insufficient on its own.
- Recovery of the Murder Weapon: The testimonies regarding the recovery of the knife were inconsistent. Witnesses failed to confirm that the knife was found at a location disclosed by the appellant, and the memorandum recording the appellant’s statement was not adequately proven, raising doubts about the authenticity of the recovery.
- Medical Evidence: The presence of glass fragments at the crime scene and the possibility that the victim’s injuries could have resulted from small, sharp glass pieces introduced reasonable doubt about the cause of death. The prosecution did not address this alternative explanation.
Conclusion
Given the insufficiency and inconsistencies in the circumstantial evidence, the Supreme Court concluded that the prosecution had not met the high burden of proof required for a conviction. The Court stated that the circumstances presented were not conclusive and did not exclusively point to the appellant’s guilt. Consequently, the appellant’s conviction was overturned, and he was acquitted of all charges.
Legal Implications
This case underscores the judiciary’s commitment to upholding the principle that an accused person is presumed innocent until proven guilty. It reinforces the necessity for the prosecution to provide a complete and unassailable chain of evidence, especially in cases relying on circumstantial evidence. The judgment serves as a critical reminder of the rigorous standards required to convict an individual, ensuring that justice is both done and seen to be done.
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