SIGNIFICANT GAPS IN CIRCUMSTANCIAL EVIDENCE: SUPREME COURT ACQUITS MAN ACCUSED OF RAPE, MURDER AND ROBBERY OF 85 YEAR OLD WOMAN

The Supreme Court of India delivered a significant Judgment in the case titled ‘Mohamed Sameer Khan v. State Represented by Inspector of Police (Criminal Appeal No. 2069 of 2024), presided over by the Two Judge Bench of Justices Dipankar Datta and Augustine George Masih, which resulted in the acquittal of Mohamed Sameer Khan. The Appeal challenged concurrent convictions handed down by the lower courts for heinous offences including murder, criminal intimidation, sexual assault and robbery. This Judgment is important as it demonstrates the Judiciary’s rigorous scrutiny of circumstantial evidence and reinforces the constitutional principle of the presumption of innocence.
Factual Background
On December 19, 2016, an 85-year-old woman who resided independently was discovered dead in her residence by her grandson. The Victim’s daughter, Deivanai and her son had established a routine of securing the elderly woman’s residence each evening following dinner service and unlocking it the following morning to enable her mobility. Upon the grandson’s entry at dawn, he discovered the door ajar and his grandmother’s body lying on the floor. The deceased bore a towel wrapped around her neck and two gold ornaments that had adorned her wrists were conspicuously absent. Medical examination revealed the cause of death to be asphyxiation resulting from neck compression. Additionally, post-mortem findings indicated the victim had suffered sexual violence prior to her demise. The investigation engaged forensic specialists including fingerprint experts and canine units, collecting biological samples and generating comprehensive documentation of the crime scene.
Contentions of the Parties
The Appellant contended that the Prosecution’s case rested entirely upon circumstantial evidence with no direct testimonial evidence conclusively establishing the Appellant’s involvement. They emphasized that the Appellant had been wrongfully implicated and that the Prosecution had demonstrated insufficient rigor in its investigative procedures. Critically, they highlighted the complete absence of scientific evidence such as DNA profiling or fingerprint analysis connecting the Appellant to the incident.
Conversely, the State’s Counsel asserted that the lower courts had correctly appreciated the evidential material. The State maintained that while the case was predicated on circumstantial evidence, the evidence collectively formed an unbroken sequence leaving no alternative conclusion but guilt. The State particularly relied upon the testimony establishing that the Appellant had exited the residential complex where the crime occurred and the subsequent recovery of the missing gold ornaments from his possession following his apprehension.
Court’s Decision and Legal Analysis
Justice Masih relied on principles derived from precedents, commonly referenced as the “panchsheel principles.” These principles mandate that the Prosecution must establish all incriminating circumstances through dependable evidence such that the circumstances create a coherent sequence permitting only one rational inference—the guilt of the Accused. The Court underscored that mere suspicion, irrespective of its strength, cannot substitute for evidence and any broken link in the evidentiary chain necessitates acquittal.
Upon subjecting the Prosecution’s evidence to this scrutiny, the Court identified several critical deficiencies. First, though a witness observed the Appellant emerging from the residential compound at approximately 2:45 a.m., he was not specifically seen exiting the Victim’s dwelling. The witness testimony established proximity rather than direct connection. Second, the investigation manifested grave lacunae, most notably the non-examination of Marcus, the sole individual who had accompanied the Appellant during the relevant window when the crime occurred. Marcus’s testimony could have illuminated the temporal duration they remained together and whether the Appellant possessed sufficient opportunity to perpetrate the offence. The Prosecution’s characterization of Marcus as immaterial appeared unreasonable given the circumstances.
Third, the recovery of the ornaments presented substantial vulnerabilities. The individual through whom the Appellant was identified near an over bridge remained anonymous and no identification procedure was conducted to establish recognition. The Prosecution’s narrative of the Appellant carrying stolen articles for two days and producing them spontaneously at a medical facility strained credulity. The Court observed that planting evidence could not be discounted. Fourth and significantly, the scientific examination proved unproductive. Despite the deployment of canine units, fingerprint specialists and collection of biological specimens, no forensic material—whether epidermal cells, hair follicles, or dermal impressions—connected the Appellant to either the victim or the crime scene.
Conclusion
The Judgment represents a decisive reaffirmation of the principle that in prosecutions dependent upon circumstantial evidence, the State bears an onerous obligation to construct an absolutely seamless evidentiary architecture. Where investigative deficiencies, witness credibility concerns, absence of scientific substantiation and unexplained investigative omissions converge, reasonable doubt must inure to the benefit of the Accused. This Judgment reinforces the judiciary’s constitutional responsibility to safeguard individual liberty against the machinery of state prosecution, ensuring that conviction demands something substantially more formidable than suspicion or circumstantial vulnerability.
YASH HARI DIXIT
Legal Associate
The Indian Lawyer & Allied Services

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