Supreme Court Yearly Digest 2025 On Murder Trial

Appellant-accused was sentenced to death for murder and rape of the victim under section 302, 376 and 397 of the IPC - Faulty Investigation - i. identity of accused could not be sufficiently protected leading to its disclosure before the TIP; ii. 9-day delay in TIP is unexplained; iii. Lack of coordination between investigating agencies and not arraying person having direct link to deceased person as witness; iv. Care requisite not taken regarding DNA evidence and large gaps in chain of custody of DNA evidence is unexplained; v. Post mortem of deceased was conducted at the spot of crime without due regard to contamination - Chain of circumstantial evidence does not point towards guilt of accused, ruling out his innocence – Held, Appellant-accused was acquitted and judgement of High Court was set aside. Appeal allowed. [Relied on Hanumant v. State of M.P. (1952) 2 SCC 71; Sharad Birdhichand Sarda v. State of Maharashtra (1984) 4 SCC 116; Para 11, 38, 42, 45] Kattavellai @ Devakar v. State of Tamilnadu, 2025 LiveLaw (SC) 703 : 2025 INSC 845 Burden of Proof - Circumstantial Evidence – Murder - Acquittal Reversal – Held, a conviction for murder can solely rest on circumstantial evidence if the chain of circumstances is complete and consistent only with the hypothesis of the guilt of the accused - When an accused offers a false explanation regarding the cause of death that took place within the confines of his house, such falsity becomes an additional link in the chain of circumstances pointing to the guilt of the accused - While the general burden of proof is on the prosecution, Section 106 applies to exceptional cases where it would be impossible or disproportionately difficult for the prosecution to establish facts pre-eminently or exceptionally within the knowledge of the accused - Supreme Court reverses acquittal of man for daughter-in-law's murder - Appeal allowed. [Relied on Sharad Birdhichand Sarda v. State of Maharashtra (1984) 4 SCC 116; Trimukh Maroti Kirkan v. State of Maharashtra (2006) 10 SCC 681; Shambu Nath Mehra v. State of Ajmer (1956) 1 SCC 337; State of West Bengal v. Mir Mohammad Omar & Others (2000) 8 SCC 382; Paras 12-21] State of Madhya Pradesh v. Janved Singh, 2025 LiveLaw (SC) 1003 : 2025 INSC 1229 Child Rape and Murder – Death Penalty – DNA Evidence – Held: Trial conducted in a flawed and irregular manner. Trial Judge erroneously permitted the investigating officer to narrate the accused's confessional statements during examination-in-chief and admitted them as evidence, violating admissibility rules. Non-examination of the scientific expert who conducted DNA profiling was fatal to the prosecution's case. Prosecution failed to establish an unbroken chain of custody for forensic samples, with unsealed samples and unverified transmission to the Forensic Science Laboratory, raising concerns of tampering. Appeal allowed; conviction and sentence set aside. [Paras 40, 47, 50, 54, 55] Karandeep Sharma @ Razia @ Raju v. State of Uttarakhand, 2025 LiveLaw (SC) 398 : 2025 INSC 444 Circumstantial Evidence and Motive - In murder trials relying on circumstantial evidence, the prosecution must establish a complete chain of evidence that eliminates reasonable doubt, but proof of motive is not mandatory. A fact is considered proved when it excludes reasonable doubt based on reason and common sense, not trivial or fanciful doubts. Circumstantial evidence must form a cohesive chain, with each circumstance independently verified, consistently pointing to the accused's guilt and excluding alternative hypotheses. The Supreme Court upheld the accused's conviction for murder based on circumstantial evidence, finding a clear pattern of evidence establishing guilt. The appeal was dismissed, reaffirming that the law requires elimination of reasonable doubt, not proof beyond all doubt. (Para 10) Chetan v. State of Karnataka, 2025 LiveLaw (SC) 657 : 2025 INSC 793 : (2025) 9 SCC 31 Circumstantial Evidence - Last seen theory - Supreme Court acquitted accused for rape-murder case, on following grounds - i. Prosecution failed to establish a clear and convincing motive; ii. Testimonies of the witnesses who claimed to have last seen the accused with the victim were unreliable due to significant delays in recording their statements and the fact that they did not see the victim with the accused; iii. The links in the chain of circumstances were broken; iv. There is strong inference of evidence planting; v. the DNA report, which was primary basis for conviction, was considered unreliable and inconsistent - Held that death penalty can only be imposed in the rarest of rare cases on unimpeachable evidence - Trial Court had not properly evaluated mitigating circumstances before awarding it and therefore, the conviction could not be sustained - Supreme Court set aside High Court's order - Appeal allowed. [Paras 10-12, 51- 56] ...

Supreme Court Yearly Digest 2025 On Murder Trial

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