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Supreme Court of India 2022-02-15 allowed

Satye Singh & Another vs State of Uttarakhand

Bench: 2 — Bela M. Trivedi

In Brief

Satye Singh and his mother Indra Devi were convicted of murdering and burning Satye Singh's wife Shashi Devi. The Supreme Court reversed both the trial court and High Court convictions. Although post-mortem evidence confirmed homicidal death (ante-mortem injuries), the prosecution failed to prove the basic facts: how, when and where the deceased was killed, or how her burnt body reached the location where found. The Court held that conviction on circumstantial evidence requires a complete, unbroken chain leading conclusively to guilt—mere suspicion, conjecture and surmise are insufficient. Since the prosecution did not establish the chain of circumstances, and an alternative explanation (suicide) remained plausible though rejected, the conviction could not stand. The appellants were acquitted.

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Criminal Law Evidence — Circumstantial Evidence Homicide Burden of Proof Dowry Criminal Procedure

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