In a case where admissible evidence is ignored, a duty is cast upon the appellate court to reappreciate the evidence where the accused has been acquitted, for the purpose of ascertaining as to whether any of the accused really committed any offense or not.

Facts

On 7 September 2011, the bodies of Mithilesh Kumari and her minor son, Bhupinder Singh, were discovered in their locked house. Post-mortem examination established that both had died homicidal deaths by strangulation. The prosecution alleged that Anchla @ Chanchla, daughter of Mithilesh Kumari’s husband from his first marriage, had committed the murders to secure the family property.

The prosecution relied upon alleged last-seen evidence, testimony concerning the accused’s taxi journey and hotel stay, recovery of keys and the deceased’s mobile phone, a DNA match between the accused’s blood and blood found at the scene, and motive. The Trial Court convicted her under S.302 IPC. The High Court set aside the conviction and acquitted her, prompting the State’s appeal.

Issues Framed

1. Whether the prosecution had proved the circumstances relied upon against the accused beyond reasonable doubt.

2. Whether those circumstances formed a complete chain pointing conclusively to the accused’s guilt and excluding every hypothesis consistent with her innocence.

3. Whether the High Court’s acquittal warranted interference by the Supreme Court.

Court’s Reasoning

(a) Last-seen evidence: The testimony of PW-1 contained material improvements over his earlier statement. His unexplained delay in reporting the disappearance, despite residing nearby, further weakened his credibility. The evidence of PW-4 and PW-18 was also found untrustworthy and could not corroborate the alleged presence of the accused at the scene.

(b) Recoveries and investigation: The prosecution failed to establish that the lock produced in Court was the one actually securing the deceased’s house. Consequently, the recovery of keys lost its evidentiary significance. The recovery of the deceased’s mobile phone was also doubtful, particularly in the absence of complete Call Detail Records (CDRs) and tower-location data.

(c) DNA evidence: The DNA match was not conclusive because the accused was a regular visitor to the house, and the possibility of her blood having been deposited there earlier could not be excluded. Her blood was not found on the victims’ clothes or the cloth allegedly used for strangulation.

(d) Motive and circumstantial chain: No evidence established the alleged bequest in favour of D-2. The medical evidence also did not conclusively establish the date of death. The cumulative deficiencies prevented the prosecution from proving a complete chain of circumstances.

Held

The Supreme Court dismissed the State’s appeal and upheld the High Court’s acquittal. It found no ground to interfere with the High Court’s assessment of the evidence.

Conclusion

A conviction based on circumstantial evidence cannot be sustained unless the circumstances are proved beyond reasonable doubt and form a complete chain excluding every reasonable hypothesis consistent with the accused’s innocence.

Relevant Para

Para 23......The general principle is that if two views are possible on the evidence adduced in the case, one pointing to the guilt of the accused and the other to his innocence, the view which is favorable to the accused should be adopted. The paramount consideration of the court is to ensure that miscarriage of justice is prevented. A miscarriage of justice which may arise from acquittal of the guilty is no less than from the conviction of an innocent. In a case where admissible evidence is ignored, a duty is cast upon the appellate court to reappreciate the evidence where the accused has been acquitted, for the purpose of ascertaining as to whether any of the accused really committed any offense or not.

Case Details

Citation: 2026 INSC 1074
Decided on: 1 October 2026
Case Title: State of Himachal Pradesh v. Anchla @ Chanchla
Court: Supreme Court of India
Bench: Manoj Misra, J.; Vijay Bishnoi, J.