Supreme Court Outlines Key Principles for Evaluating Circumstantial Evidence in Criminal Cases
Last Updated on January 13, 2025 by Amit Patra
In a landmark judgment, the Supreme Court has laid down elaborate guidelines to be followed by courts all over India while dealing with cases based on circumstantial evidence, where there is no direct evidence.
The principles have emerged from a disturbing case of rape-murder of a 9-year-old girl in Kerala in 2012. The accused, sentenced to death by the trial court and High Court, died during the pendency of his Supreme Court appeal in January 2024, but his legal heirs had pursued the case to clear his name. That provided the apex court an opportunity to articulate crucial evidentiary principles.
A three-judge bench of Justices BR Gavai, KV Viswanathan and Sandeep Mehta reiterated that courts are bound to assess the testimony of each witness in its entirety. The judgment also holds that circumstantial evidence, which draws an inference to establish a fact, requires careful scrutiny of every link in the chain of circumstances.
The Court has enunciated five principles: First, the court shall consider the evidence of each witness in its entirety. Second, reasonable inferences from testimonies must be clearly stated. Third, each link in the chain of circumstantial evidence must be proved individually and must collectively form an unbroken sequence pointing only to the guilt of the accused. Fourth, judgments must clearly explain the reasons for accepting or rejecting evidence. And finally, courts must ensure that the guilty verdict is reached only after eliminating all other reasonable hypotheses.
It thus applied these principles to look at fourteen relevant circumstances, which included evidence of the following: the last known whereabouts of the victim, suspicious activities by the accused during searches, the finding of the body in the accused’s bathroom, and most importantly, the damning DNA evidence linking him with the crime.
This judgment is an important guide for lower courts in the effect that cases relying on circumstantial evidence demand special care in assessment. The framework laid down by the Court ensures that convictions based on circumstantial evidence will be reviewed with the greatest care, ensuring that protection of the rights of the accused and interests of justice is done.
These are the principles to be laid down; in particular, the area of cases in which direct evidence is unavailable—always requiring a structured way for courts to assess circumstantial evidence while insisting on high standards of proof, characteristic of criminal cases.