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Supreme Court of India 2022-05-27 allowed

CHANDRAPAL vs STATE OF CHHATTISGARH (EARLIER M.P.)

Bench: 2 — Dhananjaya Y. Chandrachud, Bela M. Trivedi

In Brief

A couple, Kumari Brinda and Kanhaiya, was found hanged in a cashew plantation. The trial court and high court convicted appellant Chandrapal of murder under IPC Sections 302/34 based chiefly on: (1) weak extra-judicial confession of co-accused Videshi; and (2) 'last seen together' evidence showing Chandrapal called Kanhaiya into his house ten days before the bodies were found. The Supreme Court held that extra-judicial confession, being inherently weak, cannot alone support conviction without corroboration. The 'last seen' gap of ten days was too large. Critically, the medical evidence opined the nature of death was suicidal, and the prosecution failed to affirmatively prove homicidal death. Circumstantial evidence must strictly satisfy five golden principles. The Court acquitted Chandrapal, finding suspicion—however strong—cannot substitute for legal proof beyond reasonable doubt.

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Criminal Law Circumstantial Evidence Extra-Judicial Confession Murder Acquittal Last Seen Together Theory

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