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Supreme Court of India 2025-01-28 allowed

CHANDRABHAN SUDAM SANAP vs THE STATE OF MAHARASHTRA

Bench: 3 — B.R. Gavai, Prashant Kumar Mishra, K.V. Viswanathan

In Brief

A 23-year-old woman was found dead on the Eastern Express Highway on 16 January 2014. The post-mortem revealed homicidal death with genital injuries. The appellant was convicted of murder, rape, kidnapping, and evidence destruction based on CCTV footage from Lokmanya Tilak Railway Station, eyewitness accounts of sightings, an alleged extra-judicial confession to a friend, and recovery of the victim's belongings. The Supreme Court acquitted the appellant, finding the CCTV evidence inadmissible for lack of the mandatory Section 65-B(4) certificate; the eyewitness identifications unreliable due to significant delays, media publication of the accused's photograph before the identification parade, and inconsistencies; the extra-judicial confession inherently weak and unsubstantiated; and the recoveries insufficient due to infirmities in chain of custody and lack of credible explanation for retention of the victim's identity card. The Court held that the circumstances did not establish guilt beyond reasonable doubt.

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Criminal Procedure Evidence Act Electronic Records Circumstantial Evidence Extra-Judicial Confession Capital Punishment Identification Parade DNA Evidence

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