In Brief
An appellant was convicted of murder (Section 302 IPC) and causing disappearance of evidence (Section 201 IPC) based primarily on the 'last seen together' theory—that he was the last to be seen with the deceased before the latter's body was discovered with multiple burn and ligature injuries. Both trial and high courts upheld the conviction, inferring guilt from the accused's failure to explain how he and the deceased parted company. The Supreme Court set aside the conviction and acquitted the appellant, holding that the 'last seen together' circumstance alone cannot sustain a murder conviction without a complete, unbroken chain of corroborating evidence (such as motive, recovery, or forensic linkage). The Court reaffirmed that Section 106 of the Evidence Act does not relieve the prosecution of its fundamental duty to prove guilt beyond reasonable doubt; an accused's failure to explain facts within his knowledge can only be a supplementary circumstance, never the foundation of conviction. The judgment reinforced settled principles protecting against wrongful convictions in circumstantial evidence cases.
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