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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 found dead, strangled. Witnesses stated they saw him alive at 9 PM the previous evening with the appellant going on a bicycle. The appellant had argued with the victim days earlier over milk payment. Police recovered the victim's bicycle and milk can on the appellant's confession. The appellant had absconded after the incident. The trial court convicted the appellant under Section 302 and 201 IPC (murder and hiding evidence), a conviction affirmed by the High Court. The Supreme Court upheld the conviction, holding that while the last-seen theory alone is weak evidence, when combined with corroborative circumstances—such as the corpse's proximity and timing, established motive, the appellant's flight, and item recoveries—it creates a complete chain excluding any reasonable hypothesis of innocence. The appeal was dismissed.

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Criminal Law Circumstantial Evidence Last Seen Theory Murder Evidence Act Confessional Statement

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