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Supreme Court of India 2025-12-15 allowed

MANOJBHAI JETHABHAI PARMAR (ROHIT) vs STATE OF GUJARAT

Bench: 2 — Vikram Nath, Sandeep Mehta

In Brief

A man convicted of sexually assaulting a four-year-old child based entirely on circumstantial evidence has been acquitted by the Supreme Court. The Court found critical flaws: material facts were omitted from the initial complaint; the four alleged eyewitnesses were only identified after the incident through unclear circumstances; the investigation was negligent with inadequate forensic procedures; and recovery of evidence lacked proper chain-of-custody documentation. Applying the five-part test for circumstantial evidence convictions, the Court held the chain of circumstances incomplete and the prosecution's narrative unreliable. The appellant was released after nearly 13 years in prison, reaffirming that suspicion—however grave—cannot substitute for proof beyond reasonable doubt.

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Criminal Procedure Circumstantial Evidence Proof Beyond Reasonable Doubt Conviction Standards Witness Credibility Chain of Custody Forensic Evidence Investigation Practices POCSO Act Sexual Offences Against Children Appellate Review Presumption of Innocence Miscarriage of Justice FIR—Completeness and Omissions Judicial Scrutiny of Investigative Lapses Evidentiary Standards in Serious Offences

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