Supreme Court: witnesses an investigator cannot explain examining are treated as 'set up', acquittal upheld
The Supreme Court dismissed Himachal Pradesh's appeal against the acquittal of a woman, Anchla alias Chanchla, in the 2011 murder of her stepmother and minor stepbrother at Diur. The trial court had convicted her under Section 302 IPC on circumstantial evidence: the two were last seen with her; keys recovered on her disclosure statement matched a broken lock at the house; the deceased's mobile was also recovered; and a DNA profile from her blood matched blood found at the scene. The High Court of Himachal Pradesh acquitted her, and a Bench of Justices Manoj Misra and Vijay Bishnoi upheld that acquittal.
The Court found the chain of circumstances incomplete. The alleged motive, that her father had bequeathed property to the stepbrother, was never proved. Two witnesses said to corroborate her presence at the scene, a taxi driver and a hotel worker, were found untrustworthy; the investigating officer could not explain what had prompted him to record their statements at all, which the Court treated as a sign they had been 'set up' to manufacture evidence.
Tower-location data for both phones' call records, which could have shown whether the accused was near the scene, was never collected, a lapse the Court called critical. DNA matching alone did not prove guilt, since the accused was a regular visitor to the house. The Court reaffirmed that a conviction on circumstantial evidence alone requires a complete chain excluding every hypothesis consistent with innocence.
Quick checkUnder the 'complete chain' test for circumstantial evidence reaffirmed in this case, a conviction can stand only if the proved circumstances:- Make the accused's guilt merely more likely than not
- Form a chain so complete that it excludes every hypothesis consistent with innocence
- Are corroborated by a confession recorded before a magistrate
- Include at least one eyewitness to the offence itself
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Answer: B. The Court held that the circumstances must constitute a chain so complete as to rule out every hypothesis consistent with innocence, pointing conclusively to the guilt of the accused alone.
Issued by Supreme Court of India. If this summary and the source differ, the source is right — tell us and we will correct it.