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Supreme Court of India 2018-05-01 dismissed

Satpal vs State of Haryana

Bench: 3 — Navin Sinha

In Brief

A 13-year-old boy was reported missing after being last seen with the appellant going on a bicycle. The boy's body was found the next morning in a field. Two witnesses consistently testified seeing the deceased with the appellant at 9 PM the previous evening. The appellant failed to return home that night. Medical evidence indicated death by strangulation occurring approximately 24–36 hours earlier. Recovery of a bicycle and milk can based on the appellant's confession further corroborated the case. The Court upheld the conviction, holding that while the last-seen theory alone is weak, when coupled with corroborating circumstances (recovery, motive, absconding, and absence of credible defence), it sustains conviction based on circumstantial evidence if the chain of circumstances is complete and leads only to guilt.

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Criminal Law Circumstantial Evidence Murder Last Seen Theory Burden of Proof

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