Supreme Court acquits in POCSO murder case: broken chain of circumstantial evidence gives benefit of doubt

The Supreme Court acquitted a man convicted of rape and murder of his minor niece under Sections 376(2)(i), 302 and 201 of the Indian Penal Code and Sections 4 and 6 of the POCSO Act, 2012, after the Sessions Court and the Sikkim High Court had both upheld his conviction on circumstantial evidence. Applying the classical test from Hanumant v. State of Madhya Pradesh, the Court reiterated that where guilt rests on circumstantial evidence, the circumstances must be fully established and form a chain so complete that it excludes every hypothesis except the guilt of the accused. Examining each link — that the appellant was 'last seen' with the victim, the recovery of articles under Section 27 of the Evidence Act, and the DNA and forensic reports — the Court found the chain broken: witnesses were unsure whether the appellant and victim left together, the recovery spot was open and frequented by the public, and the DNA from recovered bones did not match the victim's family members at all.

The appellant's statement under Section 313 of the CrPC, being merely silent rather than false, could not by itself complete the chain. On a benefit-of-doubt standard, his conviction and sentence of life imprisonment were set aside and he was acquitted.